Document 2JQn2V8En8Vk5LJ2rXwpzg07b

1 1 In Re: 2 Solutia, et al. , 3 4 vs Case No. CV-03-PWG-134-E 5 6 McWane, et al., 7 8 9 10 11 12 April 29, 2005 13 14 30(b) (6) Deposition of SOLUTIA, INC. 15 (Witness: MICHAEL A. PIERLE) 16 17 18 19 20 21 22 23 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053272 2 1 In the United States District Court 2 For the Northern District of Alabama 3 Magistrate Judge Green 4 5 Solutia, et al., 6 .............................. Plaintiffs 7 8 vs................................. Case No. CV-03-PWG-134-E. 9 10 McWane, et al., 11 .............................. Defendants. 12 13 14 15 16 30(b) (6) Deposition of SOLUTIA, INC. (Witness: 17 MICHAEL A. PIERLE), taken on behalf of the Defendants, 18 at the offices of Husch & Eppenberger, LLC, 190 19 Carondelet Plaza, Suite 600, in the County of 20 St. Louis, State of Missouri, between the hours of 21 9:06 A.M. and 3:04 P.M. on the 29th day of April, 22 2004, before J. Bryan Jordan, Certified Court Reporter 23 No. 00532 and Notary Public, State of Missouri. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053273 3 1 APPEARANCES OF COUNSEL: 2 Joseph G. Nassif, Esq. 3 Brent Gilhousen, Esq. 4 HUSCH & EPPENBERGER, LLC 5 190 Carondelet Plaza, Suite 600 6 St. Louis, MO 63105-3441 7 Telephone: 314-480-1500 8 Direct (314) 480-1818 9 Fax 314-480-1505 10 j oseph.nassif@husch.com 11 brent.gilhousen@husch.com 12 13 FOR SCIENTIFIC-ATLANTA, INC.: 14 Bryony Helen Bowers, Esq. 15 TROUTMAN SANDERS, LLP 16 Bank of America Plaza, Suite 5200 17 600 Peachtree Street, N.E. 18 Atlanta, Georgia 30308-2216 19 Phone (404) 885-3063 20 Fax (404) 962-6686 21 bryony.bowers@troutmansanders.com Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053274 4 1 FOR WALTER INDUSTRIES AND U.S. PIPE AND FOUNDRY 2 COMPANY: 3 Shelly Ellerhorst, Esq. 4 ALSTON & BIRD, LLP 5 One Atlantic Center 6 1201 West Peachtree Street 7 Atlanta, GA 30309-3424 8 (404) 881-7000 9 Fax (404) 253-8695 10 sellerhorst@alston.com 11 12 FOR McWANE, FMC, AND UNITED DEFENSE: 13 D. Bart Turner, Esq. 14 MAYNARD, COOPER & GALE, P.C. 15 1901 Sixth Avenue North 16 Suite 2400 AmSouth/Harbert Plaza 17 Birmingham, AL 35203-2618 18 (205) 254-1238 19 Fax 9205) 254-1999 20 dturner@maynardcooper.com Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053275 5 1 FOR MEAD WESTVACO: 2 Lianne Mantione, Esq. (Appearing via telephone) 3 SQUIRE, SANDERS & DEMPSEY, L.L.P. 4 4900 Key Tower 5 127 Public Square 6 Cleveland, OH 44114-1304 7 Direct (216) 479-8471 8 Fax: (216) 479-8780 9 lmantione@ssd.com 10 11 FOR PHELPS DODGE: 12 Lynne Stephens O'Neal, Esq. (Appearing via telephone) 13 LEITMAN, SIEGAL & PAYNE, P.C. 14 600 North 20th Street 15 Suite 400 16 Birmingham, AL 85203 17 (205-251-5900 18 Direct (202) 986-5023 19 Fax (205) 323-2197 20 sls@lsppc.com Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053276 6 1 FOR SOUTHERN TOOL: 2 Ms. Allison E. McAdam, Esq. (Appearing via telephone) 3 RESOLUTION LAW GROUP, P.C. 4 3717 Mount Diablo Road, Suite 200 5 Lafayette, CA 94549 6 (925) 284-0840 7 Fax (925) 284-0870 8 allison.mcadam@resolutionlawgroup.com 9 10 11 INDEX 12 13 Examination by Ms. Bowers 14 15 16 17 18 19 20 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053277 7 1 EXHIBITS 2 3 DEFENDANT'S DEPOSITION EXHIBITS 4 Solutia-Pierle 1 ........................................................................... 12 5 Solutia-Pierle 2 ........................................................................... 13 6 Solutia-Pierle 3 ........................................................................... 47 7 Solutia-Pierle 4 ........................................................................... 64 8 Solutia-Pierle 5 ........................................................................... 69 9 Solutia-Pierle 6 ........................................................................... 83 10 Solutia-Pierle 7 ........................................................................... 90 11 Solutia-Pierle 8 ........................................................................... 96 12 Solutia-Pierle 9 ........................................................................... 97 13 Solutia-Pierle 10 ........................................................................... 98 14 Solutia-Pierle 11 ........................................................................... 103 15 Solutia-Pierle 12 ........................................................................... Ill 16 Solutia-Pierle 13 ........................................................................... 115 17 Solutia-Pierle 14 ........................................................................... 117 18 Solutia-Pierle 15 ........................................................................... 118 19 Solutia-Pierle 16 ........................................................................... 168 20 Solutia-Pierle 17 ........................................................................... 170 21 Solutia-Pierle 18 ........................................................................... 173 22 Solutia-Pierle 19 ........................................................................... 175 23 Solutia-Pierle 20 ........................................................................... 178 24 Solutia-Pierle 21 ........................................................................... 179 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053278 8 1 MS. BOWERS: Okay, we're on the record. 2 This will be the 30(b) (6) deposition of Solutia, 3 Inc., and Pharmacia, Inc., taken pursuant to notice as 4 a cross-examination of an adverse party and to be used 5 for all purposes allowed under the Federal Rules of 6 Civil Procedure. If Counsel will agree, all 7 objections will be reserved except as to form of the 8 question and responsiveness of the answer. 9 MR. NASSIF: I'm going to--whatever the 10 practice is that we've been following, I'll follow 11 that. 12 MS. BOWERS: So the usual stipulations? 13 MR. NASSIF: Yes. 14 MS. BOWERS: Okay, will the court reporter 15 please swear in the witness? 16 MICHAEL A. PIERLE, 17 of lawful age, having been first duly sworn to testify 18 the truth, the whole truth, and nothing but the truth 19 in the case aforesaid, deposes and says in reply to 20 oral interrogatories propounded as follows, to-wit: 21 EXAMINATION 22 QUESTIONS BY MS. BOWERS: 23 Q. Good morning, Mr. Pierle. 24 A. Good morning. 25 Q. My name is Bryony Helen Bowers. I'm with Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053279 9 1 the law firm of Troutman Sanders in Atlanta, Georgia, 2 and I represent Scientific-Atlanta in connection with 3 this lawsuit. Would you, please, state your full name 4 for the record? 5 A. Michael A.--Anthony--Pierle, P-i-e-r-l-e. 6 Q. Mr. Pierle, have you ever had your 7 deposition taken before? 8 A. Yes. 9 Q. When was that? 10 A. I've had it done on a handful of occasions. 11 Q. About how many? 12 A. About five, six, something like that. 13 Q. Do you remember when those depositions were? 14 A. They were 2003 and prior. 15 Q. Okay. When would the first deposition have 16 been? 17 A. Sometime in the 1960's or '70' s. What. 18 Q. Did that deposition relate to? 19 A. I think environmental matters at a plant 20 site. 21 Q. Which plant? 22 A. Actually, it was not at a plant site. It 23 was, it was around a product, shipment from a plant 24 site. 25 Q. Which product? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053280 10 1 A. You know, I don't even recall. I'm not 2 certain. 3 Q. What about the next deposition that you 4 gave? 5 A. I'm not going to remember these. I gave a 6 deposition with respect to a water pollution matter 7 sometime in the late, I think it was the late 8 Seventies. 9 Q. Can you remember any details about any other 10 depositions gave? 11 A. They were in the Eighties and Nineties that 12 dealt with, again, environmental-related matters for 13 the company. 14 Q. Were those also involving pollution matters? 15 A. Um, I'm not sure what you mean by 16 "pollution," but they were environmental-issues17 related, yes. 18 Q. Okay. Well, it sounds like you've had some 19 experience with giving a deposition, so I'm not going 20 to go into all the things that lawyers usually do, 21 telling the witness to give audible answers and things 22 like that: Sounds like you pretty much know how this 23 works, that the court reporter is taking everything 24 down, please be clear on the record as to what we're 25 saying. Do you have any questions, before we proceed Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053281 11 1 with the deposition, about how this is going to work 2 today? 3 A. No. 4 Q. Okay. Mr. Pierle, do you understand that 5 you are testifying on behalf of Solutia and Pharmacia 6 and that you have been designated as a corporate 7 representative for purposes of this deposition to 8 testify on behalf of Solutia and Pharmacia? 9 A. Yes. 10 Q. Do you believe that you are authorized to 11 speak on behalf of Solutia and Pharmacia here today? 12 A. Yes. 13 MS. BOWERS: Before we started the 14 deposition, we tried to get some consensus on how we 15 would mark exhibits today. Are we going to continue 16 with the numbers from yesterday's deposition or do we 17 just want to start over with, call this Pierle 1? 18 MR. NASSIF: Whatever you want to do, 19 really. 20 MS. BOWERS: Okay. 21 MR. NASSIF: It might be hard to continue 22 with the numbers. I think it's probably easier, you 23 probably should have marked those depositions like 24 "Solutia-Kaley" or something and have this 25 "Solutia-Pierle" so you know that it's--it is a 30(b) Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053282 12 1 (6) deposition by doing that it way. 2 MS. BOWERS: Why don't we call this 3 Solutia/Pierle 1. 4 (Defendant's Deposition 5 Exhibit Solutia-Pierle 1 6 mark'd for 7 identification.) 8 BY MS. BOWERS: 9 Q. Mr. Pierle, I'd ask you to take a look at 10 what's been marked as Solutia-Pierle 1. Have you seen 11 this document before, sir? 12 A. I have not. 13 Q. Mr. Pierle, were you given any directive by 14 anyone as to what matters you would be testifying 15 regarding today? 16 A. We--I was shown and discussed there were 17 three particular question areas that I would be 18 speaking to. 19 Q. Were those provided to you in writing? 20 A. Yes. 21 Q. Okay. Who provided those to you? 22 A. Mr. Gilhousen. 23 Q. Okay, would you turn to page 6 of what I've 24 marked as Pierle 1? 25 MS. BOWERS: Joe, what's that you've slid Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053283 13 1 over to the witness? 2 MR. NASSIF: The three areas he was told he 3 to be would be testifying about. 4 MS. BOWERS: Let's mark that as Pierle 2. 5 (Defendant's Deposition 6 Exhibit Solutia-Pierle 2 7 mark'd for 8 identification.) 9 BY MS. BOWERS: 10 Q. Mr. Pierle, looking at Pierle's Exhibit 1, 11 on page 6, I direct your attention to item number 2. 12 Is that one of the areas that you were told you would 13 be testifying regarding today? 14 A. Yes. 15 Q. And is it your understanding that you have 16 the authority to speak on behalf of Solutia and 17 Pharmacia here, today, at this deposition with regard 18 to those matters in topic number 2? 19 A. Yes. 20 Q. Okay. Same question for number 3: Were you 21 told that you would be testifying about topic number 22 3? 23 A. Yes. 24 Q. And do you believe that you have the 25 authority to speak on behalf of Solutia and Pharmacia Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053284 14 1 here, today, with respect to topic number 3? 2 A. Yes. 3 Q. Would you, please, turn to page 15 of 4 Solutia-Pierle 1? I direct your attention to item 5 number 36. Were you also told that you would be 6 testifying regarding item number 36? 7 A. Yes. 8 Q. Do you believe that you have the authority 9 to speak on behalf of Solutia and Pharmacia here, 10 today, with regard to the items in item number 36? 11 A. Yes. 12 Q. Okay. Mr. Pierle, are there any items in 13 topics number 2, 3, and 36 on Solutia-Pierle Exhibit 1 14 that you will not be testifying regarding today? 15 A. Not that I'm aware of. 16 Q. Would you, please, pass the exhibits back 17 down to the court reporter? 1 and 2? 18 (Witness complies.) 19 Q. (Continuing) Mr. Pierle, what did you do to 20 prepare for your deposition today? 21 A. I met briefly with Mr. Gilhousen and more 22 briefly with Mr. Nassif concerning the subject matter 23 of the deposition and looked at some of the documents 24 that had been made available to yourselves concerning 25 these three areas of questioning. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053285 15 1 Q. When was that meeting or those meetings? 2 A. We met on Wednesday of this week. 3 Q. Was there anyone else present at the 4 meeting? 5 A. During, kind of in and out, Ms. Debbie 6 Belleau, that I think had compiled the submissions 7 that you had received. 8 Q. Okay, so the documents that you looked at 9 during that meeting, you believe those were compiled 10 by Ms. Belleau? 11 A. I believe so, or, or she was responsible for 12 their compilation. 13 Q. About how long did your meeting last with 14 those gentlemen? 15 A. We met for about four to five hours. 16 Q. Besides those gentlemen, did you talk with 17 anyone else in preparation for your deposition? 18 A. No. 19 Q. And other than the documents that 20 Ms. Belleau gathered for your review, did you review 21 any other documents to prepare for this deposition? 22 A. No, I did not. 23 Q. Did you review any electronic data files? 24 A. No, I did not. 25 Q. Did you review any past deposition Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053286 16 1 transcripts of depositions you had given? 2 A. No, I did not. 3 Q. Did you review any depositions, transcripts 4 of anyone else's deposition? 5 A. No, I did not. 6 Q. Have you reviewed any transcripts of any 7 testimony given to any regulatory agency or court? 8 A. No. 9 Q. Did anyone review documents on your behalf 10 and provide you with summaries of those documents? 11 A. No. 12 Q. Have you met with anyone other than an 13 attorney regarding the review of documents or any of 14 the information that might be contained in those 15 documents ? 16 A. No. 17 Q. Has every document you have reviewed in 18 preparation for this deposition been provided to you 19 by an attorney or by Ms. Belleau? 20 A. Yes. 21 Q. Did you ask anyone to review any documents 22 on your behalf or to prepare, help you prepare in any 23 way for any of the topics that you would be testifying 24 regarding today? 25 A. No. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053287 17 1 Q. Have you had any meetings with anyone else 2 who was an officer, director, or employee of Pfizer, 3 Pharmacia, Solutia, or Monsanto Company to prepare for 4 your deposition today? 5 A. No. 6 Q. Have you met with any independent 7 consultants to prepare for your deposition today? 8 A. No. 9 Q. Just as a preliminary matter, in previous 10 depositions, we've come to the agreement that when we 11 refer to Monsanto, we mean Monsanto and then Solutia, 12 Pharmacia, in the progression of the company. Do we 13 have an agreement on that today? 14 MR. NASSIF: It's up to you. That's fine. 15 A. Yeah, I guess so. 16 BY MS. BOWERS: 17 Q. Okay, if at any time to answer a question, 18 you need to clarify or differentiate between those 19 entities, please let me know, just so we can be clear 20 on the record. I want to be as clear as possible when 21 we're talking about these matters. 22 What's your date of birth, Mr. Pierle? 23 A. October 24th, 1943. 24 Q. What's your current address? 25 A. 770 Gulf Shore--that' s two words --Drive, Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053288 18 1 Unit 701, Destin, Florida. 2 Q. Destin, very nice: Jealous. How long have 3 you been in Destin? 4 A. Since 1999. 5 Q. Are you retired? 6 A. Yes. 7 Q. When did you retire? 8 A. I retired from Solutia in January of 1999. 9 Q. Do you have any relatives that live in 10 northern Alabama? 11 A. Not that I'm aware of. 12 Q. Did you graduate from college, Mr. Pierle? 13 A. Yes, I did. 14 Q. Where did you graduate from? 15 A. A Bachelor's degree from Purdue and a 16 Master's Degree from Washington University in 17 St. Louis. 18 Q. What was your Bachelor's degree in? 19 A. Civil engineering. 20 Q. And your Master's? 21 A. It was a general Master's in engineering. 22 Q. Any further education, formal education? 23 A. I attended two executive management courses, 24 but those were, like, four weeks, and then eight 25 weeks. They were general management training. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053289 19 1 Q. Okay, where were those executive management 2 courses held? 3 A. The first was at the University of Texas, 4 and the second one was at Stanford. 5 Q. When you retired from Solutia, what was your 6 job title? 7 A. Vice President, Environment, Health and 8 Safety. 9 Q. What were your duties and responsibilities 10 with regard to that position? 11 A. Basically, manage the staff in these areas 12 that supported all of the business operations in 13 matters that were policy, regulatory, and some op--and 14 some operational matters with respect to the company's 15 cleanup activities. 16 Q. How long were you at Solutia? 17 A. For the--from its inception until my 18 retirement. 19 Q. So from '97-20 A. Yes. 21 Q. --through '99? And prior to '97, who were 22 you employed by? 23 A. Monsanto Company. 24 Q. What year did you start working with 25 Monsanto Company? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053290 20 1 A. In February of 1966. 2 Q. What was your first position with Monsanto 3 Company? 4 A. I worked as environmental engineer. 5 Q. What department was that in at that time? 6 A. I think it was called the Technical Services 7 Department. 8 Q. Who was the head of Technical Services 9 Department at that time? 10 A. I don't recall who was the head of that 11 whole department. 12 Q. Who was your supervisor when you first came 13 on? 14 A. When I first started, it was a gentleman 15 called Paul Hodges. 16 Q. Do you remember his job title? 17 A. I think he was just Environmental Group 18 Supervisor. 19 Q. Do you know if Mr. Hodges is still living? 20 A. He is not. 21 Q. Do you remember the names of anyone else 22 that were in a supervisory capacity in the Technical 23 Services Department in 1966? 24 A. I believe his boss was Ben Williams. 25 Mr. Hodges' boss was Ben Williams. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053291 21 1 Q. Do you know if Mr. Williams is still living? 2 A. I do not. 3 Q. What was your next job title after 4 environmental engineer? 5 A. I believe it was--the titles were kind of 6 like Engineer I, Engineer II; they were pretty 7 perfunctory kinds of things, and then I think Senior 8 Engineer was probably the next title. 9 Q. Okay, what year would you have made Senior 10 Engineer? 11 A. I believe that was 1970. 12 Q. Were your supervisors at that time 13 Mr. Hodges and Mr. Williams? 14 A. No, at that time, my supervisor was a 15 gentleman called Jack Winkler. 16 Q. Do you remember Mr. Winkler's title? 17 A. I think he was a general superintendent. 18 Q. Do you know if he is still living? 19 A. He is not. 20 MR. NASSIF: For the record, these positions 21 had nothing to do with the Anniston facility. 22 MS. BOWERS: Okay. I'm just trying to get 23 some background on the witness. 24 MR. NASSIF: I understand. 25 BY MS. BOWERS: Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053292 22 1 Q. Your next job title after Senior Engineer? 2 A. I think was Manager of Environmental 3 Protection. 4 Q. What year would that have been? 5 A. 1975. 6 Q. And who did you report to while you were the 7 Manager of Environmental Protection? 8 A. Mr. Dez Homer. 9 Q. Do you know if Mr. Homer is still living? 10 A. He is not. 11 Q. Do you remember what his title was at that 12 time? 13 A. I think it was Director of--I think it was 14 Utilities and Environmental Protection. 15 Q. And after Manager of Environmental 16 Protection, what was your next job title? 17 A. I believe it was Director of Regulatory 18 Affairs. 19 Q. And who did you report to while Director of 20 Regulatory Affairs? 21 A. Monte, M-o-n-t-e, Throdahl, T-h-r-o-d-a-h-1. 22 Q. What was Mr. Throdahl's title? 23 A. I believe he was a senior vice president for 24 Monsanto Company. 25 Q. Do you know if Mr. Throdahl is still living? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053293 23 1 A. He is not. 2 Q. And after Director of Regulatory Affairs, 3 what was your next position with the company? 4 A. I had kind of some parallel positions that 5 were virtually the same, and it was probably a 6 Director of Environmental Operations. 7 Q. What year would that have been? 8 A. Nineteen eighty--'85 or '86. 9 Q. I'm sorry, just to backtrack for a minute, 10 did I ask you what year you were the Director of 11 Regulatory Affairs? 12 A. I believe that was around 1980. 13 Q. Okay, so '85,-86, you were the Director of 14 Environmental Operations. Who did you report to? 15 A. Tom Laffrey. 16 Q. What was his title? 17 A. I don't know, he was a staff vice president. 18 I don't recall his exact title. 19 Q. Okay, do you know if Mr. Laffrey is still 20 living? 21 A. I believe he is. 22 Q. And after Director of Environmental 23 Operations, what was your next title? 24 A. Vice President, Environment, Safety and 25 Health for Monsanto Company. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053294 24 1 Q. And that's the position you held until your 2 retirement? 3 A. Well, I held it at Monsanto until the split, 4 and then basically the same title thereafter for 5 Solutia. 6 Q. Who did you report to before the split? 7 A. Nick, Nicholas Reding. 8 Q. What was his title? 9 A. Vice Chairman of Monsanto. 10 Q. Do you know if he is still living? 11 A. I believe so. 12 Q. And then after the split, did you also 13 report to him? 14 A. No, I reported to Mike Miller. 15 Q. What was his title? 16 A. I, I believe it was a senior vice president. 17 Q. Do you know if Mr. Miller is still living? 18 A. I believe so. 19 Q. Since your retirement, have you been 20 employed with any company, or as a consultant or 21 anything of that sort? 22 A. I have a, a consulting, a really small 23 consulting business, Pierle Consulting, Incorporated. 24 Q. What type of consulting do you do? 25 A. I, I did some post-retirement consulting for Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053295 25 1 Solutia for a couple of years, and then I've done some 2 very small projects in, like, 19--or around 2000-2001, 3 2002, somewhere in that time frame, basically having 4 to do with reviewing operations that were in a sale 5 transaction. 6 Q. Were you paid on an hourly basis for that 7 work that you did for Solutia? 8 A. Yes. 9 Q. Okay. 10 A. For--I'm sorry, for Solutia, I was under a, 11 under a retainer, an annual retainer. 12 Q. What were you paid annually on that 13 retainer? 14 A. For those two years, it was, I believe, 15 $50,000 a year. 16 Q. Are you currently under a retainer now for 17 either Solutia, Pharmacia, or Husch & Eppenberger? 18 A. For--with Husch. 19 Q. Is that a monthly retainer, an annual 20 retainer? 21 A. Monthly. 22 Q. What are you being paid per month on that 23 retainer? 24 A. $5,000 a month. 25 Q. Are you being paid for your deposition Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053296 26 1 today? 2 A. It's within the, within the retainer. 3 Q. Mr. Pierle, I'm sorry, I forgot to ask this 4 when we were talking about your education. What year 5 did you complete your graduate work? 6 A. I believe my degree is dated 1971. 7 Q. Okay, and your Bachelor's degree? 8 A. That was received in January 1966. 9 Q. So is it fair to say that you were with 10 Monsanto and Solutia the entire length of your career? 11 A. With the exception of one year in 1974 to 12 1975, I worked one year for the federal government. 13 Q. What did you do for the federal government 14 in that year? 15 A. I worked at the Department of Commerce in 16 their Office of Environmental Affairs. We were 17 basically part of the Department's team that reviewed 18 environmental matters that came through the 19 Department. 20 Q. What sort of things did you work on while 21 there? 22 A. They were review of environmental impact 23 statements that were being prepared by the government, 24 different sectors of the government, and also quite a 25 lot of the work was around EPA, Environmental Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053297 27 1 Protection Agency's proposed rule makings. 2 Q. Did you obtain a leave of absence from 3 Monsanto to take that position? 4 A. Um, yes. I don't know if that's the precise 5 term of what we had, but we had a--I was separated and 6 a non-employee for that, for that twelve-month period. 7 Q. Was Monsanto supportive of you taking that 8 position for that year? 9 A. Yes. The position was one at the, at the 10 Department that sort of annually rotated an individual 11 from the business community, and they were supportive 12 in me taking a year off to, to gain that experience. 13 Q. Who told you that you would be representing 14 Solutia and Pharmacia in this deposition here, today? 15 A. Messrs. Nassif and Gilhousen. 16 Q. Did anyone within the company contact you 17 with regard to your selection as a 30(b) (6) 18 representative? 19 A. No. 20 Q. Why do you believe that you were selected to 21 testify regarding items 2, 3, and 36 that we looked at 22 on Pierle Exhibit 1? 23 MR. NASSIF: Objection to the extent that it 24 calls for him to give information that was given to 25 him by counsel. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053298 28 1 MS. BOWERS: I'm merely asking for his 2 personal opinion. 3 MR. NASSIF: So to the extent that you were 4 not told why you were being selected, but on your own 5 figured out why you were selected, you can answer that 6 question if you can. 7 A. I think just simply because of my background 8 and experience at Monsanto and Solutia. 9 BY MS. BOWERS: 10 Q. Do you believe that you were the most 11 qualified person to speak with regard to these 12 matters ? 13 A. Yes. 14 Q. Is there anyone else that you believe would 15 be equally qualified to you to speak on these matters? 16 MR. NASSIF: Objection: Calls for 17 speculation on the part of the witness. 18 MS. BOWERS: I'm asking for his belief; I'm 19 not asking him to speculate. 20 MR. NASSIF: Okay, if you know that you were 21 the most qualified person, you can answer the 22 question. 23 MS. BOWERS: Mr. Nassif, I'm going to ask 24 you to quit coaching the witness. I'm going to ask my 25 questions. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053299 29 1 MR. NASSIF: I'm not coaching the witness. 2 I'm clarifying what the witness can and cannot answer. 3 MS. BOWERS: Let's let the witness decide 4 what he can and cannot answer. 5 MR. NASSIF: The witness will follow my 6 instructions. 7 MS. BOWERS: I'm not asking for 8 attorney-client communication, I'm asking for his 9 belief. 10 MR. NASSIF: And I'm explaining to the 11 witness what speculation is and isn't. 12 A. Could you repeat the question, please? 13 MS. BOWERS: I'll ask the court reporter to 14 read back the question, please. 15 THE COURT REPORTER: (Reading back) 16 "Q: Is there anyone else that you 17 believe would be equally qualified to you to speak on 18 these matters?" 19 A. I don't know how to answer that question. 20 BY MS. BOWERS: 21 Q. I'm just asking if there's anyone else that 22 you think is qualified to speak as to these matters. 23 If you don't know, you don't know. 24 A. Yeah, I mean that's what I said. 25 Q. Okay. Thank you. Did you ask anyone other Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053300 30 1 than your attorneys why you were being selected to 2 testify today? 3 A. No. 4 Q. Have you ever spoken or been asked to speak 5 on behalf of Solutia or Pharmacia before? 6 A. Yes. 7 Q. When was that? 8 A. It was, it was for Solutia in one of the 9 prior depositions. 10 Q. Do you remember what that deposition was 11 regarding? 12 A. It had to do with one of the Anniston--or a 13 matter with respect to the Anniston Plant. I don't 14 recall the case or the citation. 15 Q. Do you remember approximately what year that 16 was ? 17 A. It would have been prior to 2003, but I'm 18 not certain. 19 Q. Do you remember the name of the attorney 20 that took your deposition that time? 21 A. I do not. 22 Q. In 1966, I believe, was that the first year 23 that you came to Monsanto? Is that correct? Am I 24 remembering that date correct? 25 A. That is correct. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053301 31 1 Q. In 1966, when you came to Monsanto, was 2 there a formal document retention policy in place? 3 A. Yes. 4 Q. Do you know when that document retention 5 policy was first established? 6 A. In reviewing the matters that were submitted 7 to you, it is my understanding that they sent you the 8 full set of document retention policies within the 9 company, and I believe, or I recall that the first one 10 was in the mid Fifties. 11 Q. Okay. Who was responsible for drafting that 12 first document retention policy? 13 A. I don't recall the name. 14 Q. Do you remember what department or division? 15 A. It seems to me it was someone at that time 16 that probably was on the company, somewhere in their 17 staff--the company level staff organization. 18 Q. Okay. Can you be more specific? 19 A. No. 20 Q. Who was responsible for the implementation 21 of this document retention policy? 22 A. The implementation, as I looked at those 23 documents and then experienced them, it was a sort of 24 a top-down-through-the-organization request for people 25 to administer their files with respect to the program, Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053302 32 1 and then there was --there became a bottoms-up sort of 2 self-certification process that was gathered up to 3 note adherence through the organization with those 4 policies. 5 Q. Okay, in your top-down description, who 6 would have been the top? 7 A. I think the way the policies were written. 8 they virtually came from the top of the company, 9 probably the president, and then down through the 10 people that reported to that individual, and then 11 subsequently tiered its way down through the 12 organization. 13 Q. In the 1960's, when you came to Monsanto, do 14 you remember any one person that carried, in your 15 view, a lot of responsibility for the implementation 16 of this policy? 17 A. No, I don't. 18 Q. Okay, do you know if Monsanto ever had 19 someone who was in charge of the document retention 20 policy? 21 A. My recollection over time is that the, the 22 general administration for that may have had an 23 oversight within the Law Department, but again, it was 24 the responsibility of the business, the line operation 25 managers, and then the managers through the Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053303 33 1 organization, to request self-certification from 2 people within the company to be in accordance with 3 those policies. 4 Q. Who within the Law Department would have 5 carried this responsibility? 6 A. I believe, in looking at some of the 7 documents, the reviews of those indicated in the 8 updates of the policy were generally handled by the 9 general counsel. 10 Q. Do you remember who the general counsel was 11 in the 1960's, late 1960's? 12 A. I, I really don't. My first, you know, 13 paying attention to that personally was at a time, 14 maybe, in the Seventies and that when a gentleman by 15 the name of Ned Putzell was the, was the general 16 counsel. 17 Q. Is Mr. Putzell still living, do you know? 18 A. I don't believe so, but I'm not--certain. 19 MR. NASSIF: He's deceased. 20 BY MS. BOWERS: 21 Q. Did you ever have any conversation with 22 Mr. Putzell regarding the document retention policy? 23 A. No. 24 Q. To whom--strike that. With regard to 25 dissemination of the document retention policies at Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053304 34 1 Monsanto and then, later, Solutia, to whom was --to 2 whom were these policies disseminated? 3 A. I believe the general practice was to pass 4 these along to virtually all employees; again, down 5 through the organization. 6 Q. Was that given to an employee on his or her 7 date of hire? 8 A. I, I, I'm not certain of that. My 9 experience--and I think it was, was pretty general at 10 that time--was that when you first joined the company, 11 you spent a certain amount of time on being introduced 12 to the company and reading large numbers of manuals, 13 and that was how you generally got acquainted with 14 the, you know, the general operations of, of the, of 15 the company, recognizing, you know, that at that 16 point, you are at a pretty, pretty low level. 17 Q. So would the document retention policy be 18 given to a new employee along with other information 19 when they started work at Monsanto? 20 A. I can't say that for, for certain. 21 Q. Okay, who would know that? 22 A. I don't, I don't really know. 23 Q. Is the document retention policy updated 24 annually? 25 A. No, again, in reviewing the sequence of Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053305 35 1 those, they were --there were a series of revisions, 2 but they were, they were not annual revisions. 3 Q. How often would the policy be updated or 4 revised? 5 A. Again, there was no, as I recall, no set 6 timeline for, for doing that. 7 Q. Well, who would decide when it was time to 8 update the document retention policy? 9 A. Again, I think the general administration of 10 that was probably within the, the Law Department, 11 and--but it could have also been a determination by 12 the head of the company that, you know, when is the 13 last time we looked at it and is there a reason to, to 14 update that to make it more expansive. 15 Q. When the policy was updated or revised, were 16 notifications sent out to all employees? 17 A. Yes, I believe so, and the, and the policies 18 which were typically prepared in kind of a, as I 19 recall, a pamphlet form, you know, people would 20 receive a copy of, of those pamphlets, as well. 21 Q. Okay, how would those pamphlets be 22 distributed? 23 A. I'm, I'm not certain what you mean by that. 24 Q. Would a meeting be called and the pamphlets 25 would be handed out? Was there some sort of the Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053306 36 1 interoffice mail within Monsanto? 2 A. I would assume that, that it was up to the 3 individual, individuals in their departments to decide 4 how they wanted to distribute them, and it could have 5 been done in any number of ways. 6 Q. And that would have been the department head 7 that would make that determination of how to 8 disseminate the information? 9 A. It could have been. 10 Q. Are there separate document retention 11 policies for each department? 12 A. In looking at those, there is one general, 13 overall document retention policy that applied to 14 everyone. The level of inclusion of, let's say, types 15 of records may have varied at the department or 16 company, but it was still within the, the general 17 purview of the, of the overall policy. 18 Q. Okay. Were there any product-specific 19 document retention policies? 20 A. I believe the policies, themselves, applied 21 to a large numbers of areas that would--that could 22 have included product information, production 23 information, later to include regulatory information, 24 depending upon, as I say, the department and what 25 records they may or files they may have used in the Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053307 37 1 normal course of their business to conduct business. 2 Q. When you were the senior --excuse me, when 3 you were the vice president of the Department of 4 Environment, Health and Safety, was there a separate 5 document retention policy that your department 6 followed? 7 A. No. 8 Q. Did you supplement the document retention 9 policy of the company in any way within your 10 department? 11 A. No. 12 Q. Were employees trained, were there training 13 sessions from employees on document retention 14 policies? 15 A. Again, that, that probably varied throughout 16 the, the company. In signing the self-certification, 17 certainly, people would have had to have been aware of 18 the policy and understood it, and I can remember 19 personally at times, there would be questions asked 20 about, you know, "What does this mean," and so there 21 was probably, you know, learning going on pretty much 22 all the time. 23 Q. Okay, but are you aware of any formal 24 meetings or training sessions that were held? 25 A. No. No. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053308 38 1 Q. Are you familiar with the term or concept of 2 a litigation hold? 3 A. Talk a little more on that. 4 Q. When I say "litigation hold," I'm referring 5 to a procedure that is used within some corporations 6 where if litigation is pending or threatened, that a 7 separate document retention policy will be issued with 8 regard to documents that may be implicated by that 9 litigation. 10 A. Yes. 11 Q. Are you familiar with something like that 12 within Monsanto? 13 A. From, from time to time, there would be 14 communications with respect to certain litigation--I 15 don't remember the specifics--that materials related 16 to this matter be, sort of go outside of the general 17 retention policies towards retaining documents longer, 18 so I remember, and in many cases, those files were 19 actually, you know, asked to be sent and collected. 20 Q. Okay, how would that work? Would you 21 receive a notification from someone within the company 22 that certain documents needed to be maintained? 23 A. Yes. 24 Q. Who would send that directive out? 25 A. As I recall, those would typically come from Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053309 39 1 someone in the Law Department who I presumed, you 2 know, was more familiar with the litigation, itself. 3 Q. Would that request come in writing? 4 A. Typically, yes. 5 Q. If an employee within Monsanto received that 6 request from someone in the Law Department, what would 7 they then do with the documents? 8 A. It would, it would--would have depended on 9 the instructions in the letter received. 10 Q. Okay. Did you, yourself, ever have 11 experience with that? 12 A. Yes. 13 Q. Okay, and what did you do with the documents 14 when you received those types of notifications? 15 A. As I say, it depended on the instructions, 16 and then you followed the instructions that were in 17 the, in the specific letter. 18 Q. Okay, what were those instructions? Just 19 run me through the possibilities. 20 MR. NASSIF: Well, you are asking him what 21 the instructions were from the Law Department? 22 MS. BOWERS: Yes. 23 MR. NASSIF: I'll object on the basis of 24 privilege. You don't have to answer. 25 BY MS. BOWERS: Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053310 40 1 Q. Did you send documents--strike that. When 2 you received instructions, did you typically follow 3 those instructions? 4 A. Yes. 5 Q. Did you ever disregard those instructions? 6 A. No. 7 Q. Okay, going back to the general concept of 8 the document retention policy within Monsanto and 9 Solutia, is there any entity or department, division, 10 person on staff who is responsible for monitoring 11 compliance with the document retention policy? 12 A. Again, I'm not certain of the question. 13 Q. Okay, is there someone in charge of 14 monitoring employees' compliance with the document 15 retention policy? 16 A. I think as I described, that was basically 17 done at each level of sort of organization, so for 18 example, if I would ask my people to--for their 19 certification, then it was up to me to be satisfied 20 that, that they--that their self-certification was, 21 was appropriate. 22 Q. Okay, so the vice presidents of each 23 department and division were responsible for 24 monitoring compliance? 25 A. No, I'm saying at each level of Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053311 41 1 organization, so if someone worked for me that had a 2 group of people, then it would be up to that 3 individual to be satisfied with the certification of 4 the people in their department,-5 Q. Okay. 6 A. --and so forth, so down the organization, 7 the self-certifications came back, and it was typical 8 at each level, the person who had people reporting to 9 him would look at and gather the certifications of 10 their, what we would term direct reports. 11 Q. Was there one office, or one division or 12 department that was responsible for coordinating the 13 efforts of all of the other divisions and departments 14 with respect to the document retention policy? 15 A. Again, my indication is that those were 16 generally, the process was generally managed by 17 someone within the Law Department. 18 Q. Okay. Do you know if the Law Department did 19 any routine monitoring of employees' compliance with 20 the document retention policy? 21 A. I, I don't believe so, because again, it 22 was, it was a self-certification, and that would have 23 been the responsibility of the, of the supervisors of 24 those departments to, to be satisfied that the work 25 was done. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053312 42 1 Q. Okay, if the self-certifications were not 2 submitted, would that raise any question? Would 3 anyone come to the department head and ask about that? 4 A. I don't recall in, in my dealing with it 5 personally where there was--where the 6 self-certifications were not made, and indeed, again, 7 each supervisor would go through the step of assuring 8 that they, they were made, and then it was again my 9 boss would say "Are these all in" and send me --so 10 again, the oversight was within the management 11 structure. 12 Q. Were there any consequences for violating 13 the document retention policy? 14 A. Well, I never experienced a case where 15 somebody didn't comply with it, so you know, there 16 were general policies within the company for dealing 17 with, you know, different matters for consequences 18 with employees, but I really don't have any experience 19 and don't recall hearing any experience of anybody not 20 complying with the documents retention. 21 Q. Mr. Pierle, you are testifying today as the 22 corporate representative of Solutia and Pharmacia with 23 respect to the document retention policy, so I'm going 24 to try to be more clear in my questions, but as you 25 sit here, today, as the corporate representative with Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053313 43 1 respect to document retention policies, are you aware 2 of any consequences that were either in employee 3 manuals, any sort of handbook, any sort of written 4 rules for employees that did not comply with either 5 the self-certification process or with the general 6 rules with regard to document retention? 7 A. I don't recall any. 8 Q. Do you know who, if anyone, would know the 9 answer to that question? 10 A. No, I do not. 11 Q. Do you believe that there is someone better 12 qualified than you to testify regarding that? 13 A. I've been asked to do it, so I assume that 14 the people that have looked at that have come to that 15 j udgment. 16 Q. Is there a separate electronic document 17 retention policy? 18 A. Separate? 19 Q. (Nods head in affirmative manner). 20 A. I don't believe so. 21 Q. Okay. Is there an information technology 22 department or something similar to that within 23 Monsanto or Solutia? 24 A. There, there are, yes. 25 Q. What's that department called? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053314 44 1 A. Again, it may vary today, depending on the, 2 on the company. 3 Q. Okay. 4 A. But I think your general description of 5 information technology is--would generally capture it. 6 Q. Okay, do you know if there are manuals that 7 are produced and disseminated by the information 8 technology department? 9 A. For what purpose? 10 Q. That would contain anything related to 11 document retention. 12 A. I believe the document retention policies 13 were inclusive, and so it would be in the document 14 retention manuals not separate from the--you know, not 15 separated into another manual. 16 Q. Are you aware of any purging programs that 17 may be attached to data records kept within the 18 company? 19 A. I'm not, no. 20 Q. Do you know who would know the answer to 21 that question? 22 A. No, I don't. 23 Q. Was there a separate document retention 24 policy or policies with respect to documents that 25 would be kept for insurance purposes? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053315 45 1 A. I believe that--I mean, those matters would 2 be covered by your earlier discussion of, of 3 litigation, "litigation hold," I think you described, 4 that to the extent that they would be under 5 that--related to insurance matters, they would fall 6 under that category, as well. 7 Q. Then who would-8 A. I'm saying insurance litigation matters,-- 9 Q. Okay. 10 A. --not just insurance matters. 11 Q. So coverage issues, you would lump into that 12 category, as well? 13 A. Well, I'm thinking more of, of actual 14 litigation, so if the coverage was under a litigation 15 matter, then it would very probably be under some sort 16 of hold categorization. 17 Q. We've alluded a couple of times to the 18 Solutia spinoff from Monsanto. I believe when we talk 19 about that, we're talking about when Monsanto 20 Corporation spun off Solutia, Inc., as its own entity; 21 is that correct? Is that your understanding? 22 A. Yes. 23 Q. And that was in 1997? 24 A. Yes. 25 Q. Does either Monsanto or Solutia maintain any Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053316 46 1 documents related to that spinoff transaction? 2 A. I don't know the specific answer to that 3 question. 4 Q. Do you know if Solutia maintains any 5 documents that were Monsanto's documents? What I'm 6 getting at--I apologize; that's an unclear question. 7 What I'm getting at is when the spinoff occurred, did 8 Solutia take any documents from Monsanto when Solutia 9 became its own new company? 10 A. Um, yes. I mean, you can imagine a company 11 of that--I think there were some documents that were 12 clearly Solutia's that Solutia took, there were some 13 documents that were clearly Monsanto's, and then I 14 think there were some documents that, you know, we 15 don't have the time to figure out, we're unsure, and I 16 think there were some--they were, you know, held, 17 again, as sort of mixed documents or documents for 18 both, both entities. 19 Q. Where were those mixed documents held, or 20 are they currently being held somewhere? 21 A. I think we have prepared a list of where 22 those document centers are. 23 Q. Do you know if that list has been provided 24 to defense counsel in this litigation? 25 A. I think we're prepared to, to give that to Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053317 47 1 you. 2 Q. Okay, do you have that list with you here, 3 today? 4 A. It's somewhere. 5 MS. BOWERS: I ask the court reporter to 6 mark that document for me, please. I believe that's 7 going to be Solutia-Pierle 3. 8 (Defendant's Deposition 9 Exhibit Solutia-Pierle 3 10 mark'd for 11 identification.) 12 MR. TURNER: Joe, do you just have one copy? 13 Do you have an extra with you? 14 MS. BOWERS: We're just going to take a 15 minute to look at this document. 16 MR. TURNER: If you don't, that's fine. 17 BY MS. BOWERS: 18 Q. Mr. Pierle, if you don't mind, I'm going to 19 stand over here, since we just have one copy of this 20 document. Do you know if documents from repository 21 number 1, the Anniston Plant, have you coordinated 22 with Mr. Lamar Freeman regarding documents that may be 23 related to this litigation that are currently being 24 kept at the Anniston Plant? 25 A. I have not spoken to Mr. Freeman. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053318 48 1 Q. Do you know if anyone on behalf of Solutia 2 or Pharmacia has? 3 A. It's--I don't know the answer to that 4 question. 5 Q. Okay. 6 A. What we've prepared, here, what this was in 7 response to was a, a discussion that we had as to 8 where are files related to the two companies and who 9 are the people that would have access or control over 10 those files. 11 Q. Okay. All right. Well, let's do it this 12 way, then. Do you know what documents are currently 13 being kept at the Anniston Plant? 14 A. I do not. 15 Q. Okay. Do you know what Mr. Freeman's title 16 is? 17 A. I believe Lamar is now the plant manager. 18 Q. Okay. Is there a library or something of 19 that sort at the Anniston Plant? 20 A. A library of all retained documents? 21 Q. Just a records room; records center, if you 22 will? 23 A. I'm not certain. 24 Q. Okay, how about number 2, the Anniston 25 Community Center? Do you know what type of documents Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053319 49 1 are kept there? 2 A. I do not. 3 Q. Is that a Monsanto-owned or Solutia-owned 4 property? 5 A. I, I would--I don't know for certain. I 6 would assume not. 7 Q. Have you spoken to Mr. Branchfield about 8 what type of documents are being retained there? 9 A. I have not. 10 Q. The same with number 3, the Monsanto Company 11 Technical Library in St. Louis. Ms. Barbara--is that 12 Feldacker? 13 A. Feldacker. 14 Q. --is the librarian there. Do you know what 15 type of documents are kept at the Monsanto Company 16 Technical Library? 17 A. There are a pretty broad range of, of 18 matters there. This is a pretty good-size library 19 with a lot of the--all the confidential technical 20 documents, in many cases, that the company has ever 21 produced. 22 Q. Is that library open to the public? 23 A. No, it is not. 24 Q. Have you spoken to Ms. Feldacker about 25 documents that may be relevant to this litigation? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053320 50 1 A. I have not. 2 Q. Number 4, the Solutia, Inc., technical 3 library in St. Louis, do you know what type of 4 documents are kept there? 5 A. The, the general type of documents would be 6 the same as those that are--the same general matters 7 as would be identified in number 3; again, technical 8 documents related to the confidential property and, 9 you know, things with respect to Solutia's businesses 10 and the technical side of their, their operations. 11 Q. Is that library open to the public? 12 A. No, it is not. 13 Q. Okay. Do you, do you, or have you spoken 14 with Ms. Stockloss--Stockloosa (Phonetic) about 15 documents that may be relevant to this litigation? 16 A. I have not. 17 Q. Okay, the Washington University library in 18 St. Louis, what type of documents are kept there? 19 A. It's my understanding that those tend to be 20 generic documents that retain more to the kind of the 21 public history of Monsanto Company over time. 22 Q. Would those documents be available to the 23 public to review? 24 A. I'm not certain of the agreement, so I'm not 25 certain of the answer to that. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053321 51 1 Q. Okay. Do you--have you spoken with 2 Mr. Kempen (Phonetic) regarding documents that may be 3 at the Washington University library that would be 4 relevant to this litigation? 5 A. I have not. 6 Q. Number 6 is the--is Recall, a warehouse 7 vendor from Monsanto Company and Solutia, Inc. Does 8 that refer to a separate facility, warehousing 9 facility, or something that is not owned by Monsanto? 10 A. Yes. 11 Q. Where is that? 12 A. I don't know the specifics, other than it's 13 in the city or somewhere. 14 Q. Is Recall like an outsource records center 15 or something like that? 16 A. I believe it's--or basically describes it as 17 a warehousing vendor. 18 Q. Okay. 19 A. So they may--I mean, they may do more than 20 records, but certainly, records is part of what they 21 do. 22 Q. Do you know if Monsanto is Recall's only 23 customer? 24 A. I do not. 25 Q. Have you spoken with Mr. Garlock or Ms. Reid Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053322 52 1 regarding documents that might be at the Recall 2 warehouse? 3 A. I have not. 4 Q. And Solutia, Inc., are those 5 documents --excuse me, what type of documents would be 6 in item number 7, Solutia, Inc.? 7 A. I'm not certain. It indicates that there 8 are documents of Craig and his--Craig Branchfield, so 9 they are probably around a more narrow segment of work 10 that Craig is involved in. 11 Q. Which of these facilities have you ever been 12 to? 13 A. The, the facilities, themselves, I've been 14 to the Anniston Plant. I have been to the Monsanto 15 technical library and the Solutia technical library. 16 I have not been to the other areas, to the best of my 17 knowledge. 18 Q. Are you--thank you. Are you aware of any 19 written policy that would direct which documents would 20 be sent to which of these locations? 21 A. No, I'm not. 22 MR. NASSIF: For the record, Exhibit 3 was 23 prepared yesterday or the day before for his 24 deposition. That's why it hadn't been previously 25 produced. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053323 53 1 BY MS. BOWERS: 2 Q. Okay, Mr. Pierle, as corporate 3 representative, are you aware of any efforts taken by 4 Monsanto or Solutia to review documents at these 5 respective facilities on Solutia-Pierle Exhibit 3? 6 And when I say "review," I mean in the context of this 7 litigation. 8 A. That's a pretty broad question, so I'm--I 9 just don't know how to answer it. 10 Q. Okay. Do you know of any procedure that's 11 in place, when we get into a situation of a litigation 12 hold that we discussed earlier--I'm referring to that 13 concept we discussed earlier--when there is a 14 litigation hold, are you aware of any procedure that 15 is employed by Monsanto or Solutia to search in each 16 of these respective locations for documents that may 17 be relevant to that litigation hold? 18 A. I am not --I mean we, we discussed earlier 19 the aspect of, you know, the lawyers putting out sort 20 of a supplemental directive with respect to such 21 records, but I'm not familiar with what all they do 22 after that. 23 Q. Would those supplemental directives go to 24 vice presidents only, or would they go further down 25 the chain? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053324 54 1 A. My experience would have been they 2 would--they may have gone not broadly across the 3 company but more targeted to people that were probably 4 thought to be possible to have records. 5 Q. Okay, and when, when someone would receive 6 one of those, those notifications, would they be 7 responsible for contacting someone at each of these 8 locations to inquire as to what documents may be there 9 that would be responsive to that? 10 A. No. You were--you were basically responsive 11 to the records that were within your, let me just say 12 physical domain. 13 Q. Okay, as a vice president or in any other 14 capacity that you had at Solutia or Monsanto, were you 15 ever responsible for earmarking documents to be sent 16 to any of these facilities? 17 A. To those, those facilities? Um, no, not at, 18 not at, at that level. I mean, there were, there 19 were--and I'm only stumbling because with respect to 3 20 and 4, there were certain documents that may be 21 written because of company confidential technical 22 reports that may have ended up there, but -- 23 Q. Were all company confidential technical 24 reports supposed to go to those facilities? 25 A. I, I would say again there were--when they Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053325 55 1 were done at a time in certain formats, they were, but 2 you then said all company confidential documents, and 3 I, I don't believe that they were necessarily the 4 repository of all company confidential documents. 5 Q. Okay. What documents would you have sent, 6 in your capacity, any capacity that you had at Solutia 7 or Monsanto, what documents would you have sent to any 8 of those facilities? 9 A. I don't recall at, at the vice president 10 level, ever having sent documents to these facilities. 11 Q. Okay. Well, you are the corporate 12 representative,-- 13 A. Right. 14 Q. --testifying here about document retention, 15 so are you aware of any written directives that would, 16 that would tell us how documents got sent to each of 17 these facilities? 18 A. Well, again, I think what I described is 19 that the stuff that's created at the plant generally 20 stays at the plant. The community center, I'm really 21 not certain what's there. With respect to the 22 technical libraries, and the Washington University, 23 and Recall, that kind of dealt with whatever documents 24 were already there, you know, how they just got 25 managed through the, through the transition period, so Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053326 56 1 I don't know if that's responsive to your question or 2 not. 3 Q. Okay. What, if any, efforts were taken by 4 Monsanto, or Solutia, or Pharmacia to review documents 5 at each of these facilities with regard to producing 6 documents in this litigation? 7 MR. NASSIF: Where does that fall into the 8 scope of the three areas that he's been designated? 9 MS. BOWERS: Document retention, number 36. 10 MR. NASSIF: Document retention, number 36, 11 includes what efforts were made to produce documents 12 in this litigation? 13 MR. TURNER: We're trying to get a sense -- 14 this is the first time we've seen a list of where 15 documents are housed, so we're trying to get a sense 16 if we've ever seen documents produced from there 17 before. 18 MR. NASSIF: Okay, but I'm asking about this 19 witness and what he's been designated for. It 20 really--he really wasn't designated for what steps we 21 took to search for documents in this litigation. 22 MS. BOWERS: We're just trying to find out 23 what's in facilities 1 through 7 on this sheet that 24 you have produced. 25 MR. NASSIF: And I'm going to let you ask Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053327 57 1 those questions, but I'm saying as far as his Rule 2 30--as far as item number 36, we did not interpret it 3 for him to understand all the steps we took to search 4 those areas for documents, so if he says he doesn't 5 know, it's not because -- 6 MR. TURNER: That's fine. 7 MR. NASSIF: Okay, I just want you to 8 understand. 9 MR. TURNER: But some I've never heard of 10 before. 11 MR. NASSIF: That was handled through 12 lawyers and not necessarily Mike, so it was a little 13 different. I just don't want you to think that we 14 didn't prep him on an area that we probably should 15 have or that you might think we should have. 16 MR. TURNER: I'm trying to get a 17 clarification on those areas -- 18 MR. NASSIF: You can ask questions about 19 what steps were taken, and to the extent Mike might 20 have some information not given him by attorneys, he 21 can go ahead. 22 MR. TURNER: Those might be areas, Joe, 23 where, like I say, on first blush, a description of 24 those locations, they may have nothing to do with the 25 litigation, so -- Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053328 58 1 MR. NASSIF: You are right. 2 MR. TURNER: --if he knows, he knows. 3 not-4 MR. NASSIF: But you are free to ask. 5 MR. TURNER: Okay. 6 MR. NASSIF: Do you want to repeat the 7 question? 8 THE WITNESS: Do we have a question on 9 table, or -- 10 MR. TURNER: Is there one pending? 11 THE COURT REPORTER: (Reading back) 12 "Q: Okay. What, if any, efforts were 13 taken by Monsanto, or Solutia, or Pharmacia to review 14 documents at each of these facilities with regard to 15 producing documents in this litigation?" 16 A. And I, I don't know the answer to that 17 question. 18 BY MS. BOWERS: 19 Q. Okay, let's take about a five-minute break, 20 if we could. 21 MR. NASSIF: Sure. 22 (Recess.) 23 MS. BOWERS: Let's go back on the record. 24 BY MS. BOWERS: 25 Q. Mr. Pierle, does Monsanto or Solutia keep Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto WATER PCB-SD0000053329 59 1 records on microfilm or microfiche? 2 A. They, they have used that technique. 3 Q. Approximately, what years would that 4 technique have been employed? 5 A. I didn't get to that level of detail. 6 Q. Okay. Do you know who would know that? 7 A. Again, I think the person that helped pull 8 some of this together, Ms. Belleau, is more familiar 9 with that at that level of detail. 10 Q. Okay, do you know who Ms. Belleau would have 11 worked with within the company to obtain all these 12 documents and records? 13 A. I think these, these were the list of people 14 that she has been working with to gather up and to 15 submit to you what you've received. 16 Q. Okay, and those are the individuals on 17 Pierle-Solutia 3? 18 A. That's correct. 19 Q. Okay. Do you know if there is a microfilm 20 or microfiche library of sorts within the company? 21 A. I don't recall any separate retained library 22 for that. 23 Q. Do you know who was the custodian of the 24 microfilm and microfiche? 25 A. Again, I don't know that it existed Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053330 60 1 separately. 2 Q. Did each plant maintain their own records 3 repository, or library, or records center? 4 A. I think it was up to the plants to decide 5 where they kept records, but in, in general, since the 6 policy referred to, you know, records, it would have 7 included records within departments and people's own 8 personal domain. I don't recall a separate--and this, 9 again, is not general, but in specific at, at plants, 10 a specific repository for records. 11 Q. Did the plants--was there any sort of 12 regular procedure whereby plants would send documents 13 to St. Louis? 14 A. Not that I recall. 15 Q. Were there any records that a plant had to 16 send to St. Louis, in the regular course? 17 A. That's, again, a pretty, pretty broad 18 question. I, I don't know the specific answer to 19 that. 20 Q. Are you aware of any documents that would be 21 generated at the plant level that, because of Monsanto 22 or Solutia's document retention policy, had to be sent 23 to a central location? 24 A. No. An exception to that is I think from 25 time to time, we did have plants that were sort of Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053331 61 1 shut down, and at that time, it was, I think it was 2 sort of general that those records would come to 3 St. Louis, but that, that didn't mean necessarily to 4 a, you know, a set, specific place in St. Louis. 5 Q. Were there any directives from--when I say 6 "St. Louis," I'm obviously referring to corporate 7 headquarters--were there any directives from the 8 corporate headquarters in St. Louis as to how a plant 9 should set up or maintain its recordkeeping? 10 A. No, again, the policies that you've looked 11 at basically dealt with types of documents and 12 classifications and then years of retention. 13 Q. But there were, there were no directives on 14 how a records center should be set up or maintained? 15 A. I did, in perusing some of those documents 16 early on, see that there was --and I was sort of amused 17 at it --there was a very specific kind of "Organize 18 these boxes and these letters, " and-- 19 Q. I saw that, too. 20 A. And that was around the time that the 21 company was actually pulled together into its first 22 corporate world, kind of worldwide headquarters in the 23 mid Fifties, so I suspect they, they had noble 24 ambitions as to -- 25 Q. If a plant ceased making a product, would Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053332 62 1 those documents related to that product or the 2 cessation of making the product be sent to St. Louis? 3 A. I don't know the specific answer to that. 4 Q. Do you know who would know the answer to 5 that? 6 A. No, and, and again, I think there was again 7 a subject of how long those records would be retained, 8 so they could have been retained in place consistent 9 with those, you know, with the documents retention 10 period, but I would also say that, you know, your 11 question is very general, so I don't know-- 12 Q. And I'm intentionally trying to be very 13 general, at this point,-14 A. Okay. 15 Q. --so I'm asking, you told us that when a 16 plant would shut down, those records would be sent to 17 St. Louis, so I'm trying to get a little more 18 specific. When a product line was shut down, would 19 those records be sent to St. Louis? 20 A. I don't know the specific answer to that 21 question. They wouldn't have to be because they're, 22 you know, there's still a plant and an existing 23 operation there. 24 Q. Did the document--did each plant or facility 25 have its own document retention policy that layered on Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053333 63 1 top of the Monsanto or Solutia document retention 2 policies? 3 A. No, the--again, the policy was applied to, 4 to everyone. The specifics were really around in the 5 types of records that were kept and may be different 6 from location to location, but the policy applied to 7 all of those. 8 Q. Were plant managers authorized to come up 9 with their own document retention policies? 10 A. No. 11 Q. Do you know if there's one location or one 12 or more locations within Solutia or Pharmacia where 13 documents related to PCBs are kept? 14 A. I, I don't know the answer to that question. 15 Q. Do you know who would know the answer? 16 A. I would think that the law firm would. I 17 don't know the answer to that question. 18 Q. Is there someone within the company, not an 19 attorney or Ms. Belleau, that would know the answer to 20 that question? 21 A. I don't believe so. 22 Q. When the Anniston Plant ceased producing 23 PCBs--I believe it was in the early 1970's--do you 24 know if there was a litigation hold related or 25 insurance hold related to those documents regarding Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053334 64 1 PCB production or the cessation of PCB production? 2 A. I don't know. 3 Q. Do you know who would know that? 4 A. No. 5 Q. I'm going to hand you a stack of documents. 6 I'd like to get the court reporter to mark this as 7 Composite Exhibit Solutia-Pierle 4. 8 (Defendant's Deposition 9 Exhibit Solutia-Pierle 4 10 mark'd for 11 identification.) 12 BY MS. BOWERS: 13 Q. (Continuing) I'd ask you just to take a 14 quick look through this document and tell me if you've 15 seen it before. 16 (Witness peruses said 17 exhibit.) 18 BY MS. BOWERS: 19 Q. Are you familiar with this document, 20 Mr. Pierle? 21 A. This is a pretty thick thing, so I haven't 22 had a chance to look at-23 Q. Okay. 24 A. --at all of this. 25 Q. Well, just let me know when you are ready. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053335 65 (Witness continues to peruse said exhibit.) A. I think I perused documents that are similar to this. Q. Okay. I'd ask you to flip three pages into the document, page that reads, "Records management 7 program contact representative manual Monsanto 8 Chemical Company." 9 A. Are we in the-10 Q. In the first section . There's a Bates stamp 11 at the bottom-12 A. Okay, I have it. 13 Q. --ADAD3-000003. 14 A. I have it. 15 Q. What is a contact representative? 16 A. I'm not certain. 17 Q. I ask you to flip to the next page, where it 18 says, " Introduction." 19 A. There's a blank page in here. 20 Q. Okay. Then it would be your next page, the 21 page that says, "Introduction" ? 22 A. Yes . 23 Q. This document purports to be a, a records 24 management program manual, if you will. Do you have 25 any reason to believe that this is not a records Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto WATER PCB-SD0000053336 66 1 management manual for Monsanto Corporation? 2 A. No. 3 Q. The third sentence of this document, "The 4 success of forms control is largely due to the work of 5 contact representatives," do you know what forms 6 control is? 7 A. I do not. 8 Q. Do you know who would know that? 9 A. Not other than Mr. Flanagan. I'm not 10 familiar with that specific term. 11 Q. Okay, Mr. Flanagan's title I know is General 12 Office Manager. Are you familiar with that job title 13 or position? 14 A. I, I don't know what it was in the context 15 of this time frame. 16 Q. What is your understanding? Is there a 17 present-day General Office Manager of Monsanto or 18 Solutia? 19 A. There was a--typically for this general 20 offices site, there was, like, a site manager or 21 general offices manager, and that person was primarily 22 responsible for the physical plant aspects of the 23 site, which may include, you know, security, and 24 maintenance, and power, and utilities, and that sort 25 of thing. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053337 67 1 Q. So do you believe that this manual that 2 we've marked as Composite Exhibit Solutia-Pierle 4 3 would be a plant-specific manual? 4 A. No, I believe this was --as I've read this, 5 this was the company-wide records management program 6 that was being introduced across the entire company. 7 Q. Okay. Mr. Flanagan refers in this 8 introduction to "If you are a contact representative 9 for both the forms and records programs, this manual 10 may be inserted in the same binder." Does that in any 11 way refresh your recollection as to what a contact 12 representative was? 13 A. What it, what it basically sounds like is 14 that at--and it looks like at a receiving location, 15 there was somebody designated to kind of coordinate 16 the implementation of this program at a particular 17 site. That was the contact person they would go to 18 to--for communications and for implementation. 19 Q. Do you know how contact representatives were 20 selected? 21 A. I do not. 22 Q. Do you know of any qualifications that a 23 person would have to have to be selected as a contact 24 representative? 25 A. No. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053338 68 1 Q. Do you know if contact representatives were 2 paid additional compensation for performing this role? 3 A. No. 4 Q. Do you know if there is a list of, 5 historical list of some sort that would have the names 6 of people that served as contact representatives? 7 A. No. 8 Q. Do you know who would have supervised the 9 contact representatives? 10 A. It appears that Flanagan may have been kind 11 of their, their group for purposes of communications, 12 but for purposes of supervision, job performance and 13 that, no. 14 Q. Do you know if there was one or more contact 15 representative within each department or division of 16 the company? 17 A. No, I do not. 18 Q. In this same section of documents, I'd like 19 you to flip--there's page numbers are probably the 20 easiest; page number 6. 21 A. Numerical 6? 22 Q. Numerical 6, yes. Under that first bold 23 heading, "Records Center Facilities and 24 Specifications, 25 A. Mm-hmm? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053339 69 1 Q. --this document refers to a General Office 2 Records Center. Do you know where the General Office 3 Records Center was? 4 A. It would have--I do not know the specific 5 location. Clearly, it would have been at the general 6 offices, again which, as I said, was sort of being 7 under constructing--construction as I recall at the 8 same time,-9 Q. And that's St. Louis? 10 A. At the Creve Coeur campus. 11 Q. Okay. Do you know what department or 12 division the General Office Records Center would have 13 been under? 14 A. I don't know specifically. 15 Q. Do you know who would have headed up the 16 General Office Records Center? 17 A. I do not, unless it was Mr. Flanagan. 18 Q. Was there a company librarian or a company 19 archivist that would have been in charge? 20 A. I don't know. 21 MS. BOWERS: That's all I have with this 22 stack. 23 (Defendant's Deposition 24 Exhibit Solutia-Pierle 5 25 mark'd for Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053340 70 1 identification.) 2 MS. BOWERS: I'd like to ask the court 3 reporter to mark--the court reporter has just marked 4 Solutia-Pierle 5. Mr. Pierle, would you take a look 5 at this document and let me know when you've had 6 sufficient time? 7 (Witness peruses said 8 document.) 9 A. I've read the initial page. 10 Q. Do you have any reason to believe that this 11 document is not what it purports to be, a records 12 management manual of Monsanto Company? 13 A. It's a double-negative, so I want to make 14 sure I-15 Q. I'm sorry. Do you-16 A. I believe it is a document of Monsanto. 17 Q. Okay. Would you flip to the fourth page of 18 this document, please? There's a Bates stamp at the 19 bottom, ADAD 3-000304? 20 A. I have it. 21 Q. The fourth paragraph down, "Division and 22 central department management shall be responsible for 23 conformance with this standard, " who does that refer 24 to, "Division and central department management"? Who 25 would those people have been, job titles or names, if Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053341 71 1 you can remember them? 2 A. No, the--I'll answer the first part of it. 3 I don't recall the specifics on the second question, 4 but at that time, the company, below the, sort of the 5 chief executive or president, whatever the title was, 6 would have been a set of business divisions and then a 7 set of central staff departments, and I think that's 8 the, that's the designation there, and goes back to 9 the comment I had made about these being implemented 10 sort of the down from the--through their 11 organizational entities. 12 Q. Okay, so by "division management," for 13 example, what were some of the names of the divisions? 14 A. Again, this was what--as my understanding, 15 we've furnished a large number of organizational 16 charts, so rather than kind of guess at that, you'd 17 have to go back and look at a '67 company organization 18 chart and that would probably delineate the division 19 names and department names,-- 20 Q. Okay. 21 A. --and in some cases, may even include the 22 heads of those units. 23 Q. Okay, and by "Central department," those 24 would also be reflected on those organizational 25 charts? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053342 72 1 A. They should be. 2 Q. Okay, were all departments central 3 departments, or is "central department" a subset of 4 departments ? 5 A. Again, that--the terminology, I think 6 "Central" refers to company-wide in that case, so it 7 would have been sort of a company-wide department, 8 mainly a staff unit or a staff grouping that reported 9 to the head of the company. 10 Q. And on the next page, please, the last three 11 digits, 305, item number 5, "Office versus records 12 center retention," where was the records center that 13 this refers to? 14 A. I think in the earlier document, when they 15 were, it looks like, beginning to set this up, there 16 was some enthusiasm around this more digitalized 17 records center, as opposed to office, which would be 18 the individual's domain. I think that's the 19 delineation that is described here. I don't recall, 20 though, whether, you know, those records centers 21 actually existed or existed for how long. 22 Q. Okay. Well, in terms of geography, was 23 there a records center at each plant, or was there 24 one, one main records center within the company? 25 A. I think what was called out was there was to Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053343 73 1 be a records center, you know, like at a location, so 2 to the extent that they were creating a company 3 location, there would be a records center, but at a 4 plant site, I think at least initially, there was an 5 expectation there would be a records center, as well 6 as office centers. 7 Q. So there would be a records center within 8 each plant and then a records center in St. Louis, as 9 well? 10 A. It looks like that's what was contemplated. 11 Q. Would someone within the corporate St. Louis 12 structure supervise or monitor the creation of a 13 records center at the plant, or would that be within 14 the purview of the plant manager? 15 A. That would have been at the plant level. 16 Q. Then on the next page, 306, there is a 17 reference in item number 8 to company libraries. What 18 were the company libraries? 19 A. Again, I think this is speculative; in the 20 event that there are libraries or where there are, you 21 have to recall back at this time, Monsanto had 22 been--was not a centrally located company, so some of 23 the business divisions did not operate out of 24 St. Louis, and to the extent that they had technical 25 documents, and libraries, and all of that, it would Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053344 74 1 have been wherever those businesses were, were 2 operating out of. 3 Q. Okay. This document purports to be from 4 1967 . 5 A. Right. 6 Q. How many libraries did Monsanto have in 7 1967? 8 A. I don't know. 9 Q. Do you know who would know that? 10 A. No. 11 Q. Do you know if there are any documents 12 within the company that would evidence how many 13 libraries there were in 1967? 14 A. No. 15 Q. Do you know what--in what geographic 16 locations any of these libraries may have been 17 located? 18 A. Again, the liberal discussion of libraries, 19 I don't know the specific answer to that question. It 20 could have been libraries, you know, potentially at 21 each plant and at each general business operation 22 point. 23 Q. Are you aware of any document that would 24 show which plant had libraries and which plants did 25 not? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053345 75 1 A. No. 2 Q. Who would run these libraries? 3 A. I don't know. 4 Q. How would the libraries get their money to 5 operate? 6 A. Again, I don't know for certain, but it 7 would have come out of the location, the location cost 8 centers or budgets. 9 Q. So if there were a library at a plant, it 10 would come out of the plant's budget? 11 A. I would, I would think so, yes. 12 Q. Were these libraries open to the public? 13 A. No. 14 Q. What sort of things would, would you--what 15 sort of things would be found in the libraries? 16 A. Well, I think it's described at, at least 17 generically on the page you had pointed me to; could 18 be general things, books, reference sources, 19 periodicals, pamphlets, you know, they could be in 20 there that are not covered by this. The other thing 21 that would have been in here would have, again, 22 been--it probably varied site to site but would have 23 included, probably, technical reports and confidential 24 information relative to that site. 25 Q. I direct your attention to item number 9 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053346 76 1 with respect to archives. Where were the Monsanto 2 Company archives maintained? 3 A. Again, that was predominantly at the, the 4 St. Louis corporate headquarters. 5 Q. What type of documents, what sort of 6 documents would be found in the Monsanto Company 7 archives? 8 A. I can only tell you personally, I mean there 9 at one time at the site, there was a display of old 10 memorabilia, you know, the president--initial 11 president's desk, film footage of Monsanto Company, 12 you know, just old historic stuff that was of, in many 13 cases, general matters. Other stuff in the archives, 14 whether there had been, I'm not familiar with that. 15 Q. From the period of 1967 forward to the 16 present, has the Public Relations Department always 17 maintained responsibility for the company archives? 18 A. I'm not certain of that. 19 Q. Do you know who the Public Relations 20 Department director or vice president in charge of 21 public relations would have been in 1967? 22 A. No, I don't. 23 Q. How about at any point since 1967? 24 A. Well, for a period of time, a gentleman 25 called by the name of Dan Bishop headed that up. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053347 77 1 The--generally, the Public Relations Department 2 effort, but I mean that changed periodically within 3 the company's history. 4 Q. Do you know if that gentleman is still 5 living? 6 A. Dan is not. 7 Q. Is there a company archivist, or librarian, 8 or someone that would be charged with actually running 9 the day-to-day operations of the Monsanto Company 10 archives? 11 A. I'm not certain. I think on the list that 12 we provided was primarily the areas where the 13 documents and that sort of thing are. A lot of the 14 historic memorabilia I think got split up, and as I 15 think I indicated earlier, some of that went to that 16 Washington University place that is also on Exhibit 3. 17 Q. Would you, please, turn to the Bates stamp 18 page that ends in 338? 19 A. I have it. 20 Q. I'm looking at Item number 3 on this page, 21 "Litigation and claims," and I'll just tell you, I 22 know from looking at page 4 of this document that "CP" 23 means "completion." Do you know who would identify 24 when a litigation and claim matter would reach 25 completion and thus could be destroyed pursuant to Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053348 78 1 this document retention policy? 2 A. I think that specifically refers, here, to 3 the legal, sort of central department, I believe, so 4 that determination would have been made there. 5 Q. Okay, what if litigation hadn't actually 6 begun but issues had been identified with respect to a 7 matter that may go to litigation? Would that fall 8 within this litigation and claims section on this 9 document retention policy? 10 A. I don't know. 11 Q. Do you know who would know the answer to 12 that? 13 A. I do not. 14 Q. I ask you to flip to the next page, item 15 number 7, "Pending claims," refers to "Year-end report 16 to auditors." Do you know what that refers to? 17 A. I do not. 18 Q. And item number 10 on this same page, 19 "Compliance investigations," would that item refer to 20 environmental compliance issues? 21 A. I would assume so, yes. 22 Q. Who would make the determination of "While 23 useful only" as indicated on this document? 24 A. Again, this was pertaining to the Legal 25 Department, so it would have been someone in, in the Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053349 79 1 Law Department. 2 Q. I ask you to flip to the next page, Bates 3 stamp 340, item number 4. With respect to 4 manufacturing data, who would make the determination 5 "Until purpose is served"? 6 A. Um, again, that would have been in the 7 manufacturing organization, and it, it would have been 8 the, the person I would think that held the records. 9 Q. What does, what does "Until purpose is 10 served" mean with respect to this policy? 11 A. I think the answer to that could probably 12 vary between the individual sector or records, but for 13 example, under this one, where you'd say "Batch 14 records," well, when you no longer need a batch record 15 and its purpose was served for having that batch of 16 that particular lot of materials, the reason you kept 17 it, once that purpose was served, you could then get 18 rid of the record. 19 Q. So -- 20 A. So it would depend on why you were, why you 21 were taking--not keeping a record but why were you 22 initially, you know, keeping that information, and 23 once the purpose had been served, then you wouldn't 24 have--would no longer have to keep the record. 25 Q. So there was no one person that had ultimate Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053350 80 1 responsibility for deciding "until purpose is served"? 2 A. No, again, again on the self-, sort of 3 certification process that, that could have been, you 4 know, thousands of people in the company. 5 Q. Do you know if there are still documents in 6 existence related to the processing of PCBs? 7 MR. GILHOUSEN: You are getting outside the 8 scope of what Mike is here on, the record retention. 9 You are talking about the process of PCBs. You may 10 want to rephrase that. 11 MR. TURNER: Documents reflecting-12 MS. BOWERS: I'm asking for documents, and 13 we have an open-ended, "Until purpose is served" 14 destruction order here, or retention time, and I'm 15 just asking if he knows if there are still documents 16 in existence related to the processing of PCBs. I'm 17 not asking to get into the content of those documents. 18 MR. GILHOUSEN: Okay. If you know. 19 A. I know that the lawyers have certain 20 documents with respect to PCB matters. I don't know 21 whether that at all relates to the, the specifics 22 under item 4. 23 BY MS. BOWERS: 24 Q. Okay. Would you, please, flip to Bates 25 stamp 347? I'm specifically looking at item number 6. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053351 81 1 Under the "Total retention time," referring back to 2 the key on page 4, "T" means "terminated." Do you 3 know if there are toxicology data or reports related 4 to PCBs that are still in existence? 5 A. Again, I believe the lawyers have 6 those--have--if there are documents, the lawyers have 7 those documents. 8 Q. Same question with respect to lead. 9 A. I think the same answer would apply, the 10 difference being I don't think Monsanto ever made 11 lead. 12 Q. Bates stamp page 372, please, looking at 13 item number 4, specifically the second paragraph of 14 item number 4, who would decide that a record would 15 likely be evidence for litigation? 16 A. Again, I, I would think that determination 17 would be made in the Law Department. 18 Q. Bates stamp page 382, please, I'm looking at 19 item number 3, which makes reference to a Director of 20 Records. What department or division would the 21 Director of Records be in? 22 A. Is this still part of this 1967 document? 23 Q. I believe so, yes. That's how it was 24 produced to us, and it appears--it's page 80 of that 25 document. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053352 82 1 A. Yeah, and I think it indicates, there, the 2 designee of the corporate secretary, which would have 3 been, again, the Legal, Law Department unit. 4 Q. The corporate secretary was with the Legal 5 and Law Department? 6 A. I think in general, the general counsel was 7 typically the corporate secretary. 8 Q. Okay. 9 A. That would be corporate--you know, the 10 corporation. 11 Q. Okay, but my question was about the Director 12 of Records. 13 A. Well, you asked who, who he would have been 14 under, reporting to,-15 Q. Right. 16 A. --and that was my answer. 17 Q. Okay, would the Director of Records have 18 been an attorney? 19 A. Um, in looking at this, I believe I know 20 this individual or I knew of this individual, 21 Mr. Dunlop. I don't--I don't know for certain. I 22 don't believe he was an attorney. 23 Q. But he was within the Law Department? 24 A. That's what this appears to indicate. 25 Q. Do you know the names of any other Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053353 83 1 individuals who served as the Director of Records? 2 A. No. 3 MS. BOWERS: That's all I have on this one. 4 (Defendant's Deposition 5 Exhibit Solutia-Pierle 6 6 mark'd for 7 identification.) 8 BY MS. BOWERS: 9 Q. Mr. Pierle, I'd like you to take a look at 10 what we've marked as Solutia-Pierle Exhibit 6. This 11 purports to be a Standard Record Retention Schedule 12 Section 1 of the Records Management Manual of Monsanto 13 for the year 1970. Do you believe that that's what 14 this document is? 15 A. Yes. 16 Q. Would you, please, flip to Bates stamp page 17 the last three digits 417? I'll represent to you that 18 it appears to me from my review of the documents in 19 preparing for this deposition that this was the first 20 section I found regarding computer and data processing 21 records retention. Are you aware of any data 22 processing or computer record retention policy that 23 would have predated November of 1970? 24 A. No. 25 Q. Would you, please, flip to Bates stamp page Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053354 84 1 439? With regard to item number 1, "Process or 2 facility operating manual," these items are marked 3 under "Total retention time," "T," product, I read 4 that "termination of the product plus ten years." Do 5 you concur with my reading of that? 6 A. Appears to be correct. 7 Q. By "product," what is meant there? 8 A. Um, I'm not a hundred percent certain, but 9 it would, it would appear to indicate, you know, just 10 what it says. It's a product, one of the Monsanto 11 Company products. 12 Q. How would, how would individuals that would 13 hold these records be informed that a product had been 14 terminated? 15 A. Well, this is at a manufacturing facility, 16 so if they are no longer making it, that would be 17 possibly one indication for them with respect to that 18 product. 19 Q. Would a memo of some sort or a directive go 20 out saying "FYI, we're not making this product 21 anymore"? 22 A. I mean, it would, it would have been--I 23 guess I'm not trying to be flip, but it would have 24 been self-apparent to them if they were not making 25 that product. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053355 85 1 Q. Would there be any procedure where all these 2 records would be gathered in one place with respect to 3 a terminated product? 4 A. Again, a similar response sort of with 5 respect to a mention on plant shutdowns. There may 6 have been an attempt to pull some repository, but that 7 would have been more specific than this. I think this 8 is guidance to the people at the plant site that if 9 you are not making the product, you can get rid of the 10 records after ten years after you've stopped making 11 it. 12 Q. Would you, please, turn to Bates stamp page 13 446? Specifically, item number 7? Would item number 14 7 encompass environmental compliance-type documents? 15 A. This was in 1970, I believe, this manual, 16 and during that time frame, it probably did not. 17 Q. Would there have been a separate policy with 18 respect to those documents? Or excuse me, a separate 19 department or division that would have been 20 responsible? 21 A. I think as you go through here, there 22 were--there was an evolution of distinctions on 23 keeping records with respect to environmental matters, 24 in the Seventies, there were some but not many, and as 25 it grew the records, but, but those would have been Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053356 86 1 primarily on compliance basis, since the issues would 2 have been, at plant sites would have been part of the 3 plant recordkeeping procedures. 4 Q. Describe for me, if you will, that evolution 5 of keeping the environmental compliance records 6 throughout the 1970's. 7 A. I'm not sure that's what I said. 8 Q. Okay. Well, please clarify. 9 A. Well, what do you--what is it that you, you 10 need? 11 Q. What is the first point in time that you 12 were aware of Monsanto keeping environmental 13 compliance-type records? 14 A. I don't know the answer to that question. 15 Q. Who would know the answer to that question? 16 A. It would be, again, dependent upon who had 17 to comply, and where, and at what location, so to the 18 extent that those records existed, it would have been, 19 you know, at plant location records. 20 Q. So it would have been facility by facility? 21 A. That's where compliance generally happened, 22 that's correct. 23 Q. Okay, is there now, at the present time or 24 when you left the company, was there a, a central 25 repository, or a central department or division that Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053357 87 1 was responsible for keeping watch over all these 2 environmental compliance matters at each individual 3 facility? 4 A. Well, I guess my question is what does that 5 have to do relative to records retention? That's, 6 that's a question of whether we had a program, and 7 it's not asking a question about what was our policy. 8 Q. Frankly, it's a hybrid question of items 9 number 2, 3, and 36. You've also been designated as 10 the corporate representative to talk about plant 11 manager and other key management personnel with 12 respect to the responsibility for environmental health 13 and/or safety matters at the Anniston facility, and 14 you've also been identified to testify regarding plant 15 corporate level organizational structure relative to 16 the environmental health and/or safety matters at the 17 Anniston facility throughout its operational history, 18 so I'm--in an attempt to get this deposition done as 19 quickly as possible, I'm mixing my questions, here, 20 I'm asking questions about organizational structure 21 while I'm asking questions about document retention. 22 I'm happy to save all those questions until then if 23 you'd like, but in the interest of time, I'm trying to 24 get answers to those questions. 25 MR. NASSIF: Well, then, answer the question Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053358 88 1 as to the Anniston facility if you want, Mike, if you 2 understand the question, just ask it in the context of 3 the-- 4 THE WITNESS: If you could repeat it again. 5 MS. BOWERS: The court reporter will repeat 6 my question. I'll try to rephrase to be Anniston and 7 corporate level specific. 8 THE COURT REPORTER: (Reading back) 9 "Q: Okay, is there now, at the present 10 time or when you left the company, was there a, a 11 central repository or a central department or division 12 that was responsible for keeping watch over all these 13 environmental compliance matters at each individual 14 facility?" 15 BY MS. BOWERS: 16 Q. Mr. Pierle, building on that question that 17 the court reporter has just read back, with respect to 18 Anniston, the Anniston facility, at any point in time 19 or at what point in time did environmental compliance 20 records that would have been generated and kept at the 21 Anniston facility, did those documents ever get sent 22 to some central department or division in St. Louis? 23 A. The basic responsibility for compliance was 24 at the plant site, and for keeping and documenting 25 compliance was at the point of compliance, and I'm not Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053359 89 1 aware that there was a, a requirement or request to 2 centralize or to, you know, keep those records over 3 time someplace else. 4 Q. Did the Department of Environment, Health 5 and Safety that you were the vice president of, did 6 you have any interaction with the Anniston Plant while 7 in that role, or did your predecessors in that 8 department have interaction with Anniston in regard to 9 environmental compliance issues? 10 A. Yes. 11 Q. At what point in time would that interaction 12 have started? 13 A. The Anniston Plant, over time, was in 14 different organizational parts of the company. You 15 could see that in looking through what you've been 16 sent, and over time, the assistance of either a 17 division or a unit person to help understand 18 environmental matters and those things, there did 19 begin to appear within the organization people outside 20 the plant to help people with those matters. That was 21 predominantly in the late Seventies, and so there was 22 some help and review there, but the understanding of, 23 for example, permits and compliance requirements again 24 was, was, was still a plant responsibility. 25 Q. What were some of the names of these Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053360 90 1 individuals in the late 1970's that would operate in 2 this helper-type role that you've just described? 3 A. With respect to the Anniston Plant? 4 Q. Yes. 5 A. The first individual that I can recall in 6 that role, I think, was a gentleman by the name 7 of--and I may be wrong on this--Don Maynard. 8 Q. Is Mr.--I'm sorry, go ahead. Is Mr. Maynard 9 still living? 10 A. I'm not certain. I don't believe so, but 11 I'm not a hundred percent certain of that. 12 Q. Do you remember the names of anyone else in 13 the late 1970's or even into the 1980's that would 14 have operated in this helper-type role with respect to 15 the Anniston facility? 16 A. Don had that role for a long time. Hmm. It 17 seems to me the next guy may have been Dennis 18 Redington. 19 Q. Approximately what year would Mr. Redington 20 have taken over those responsibilities? 21 A. I think that was into the Eighties. 22 Q. Do you know if Mr. Redington is still alive? 23 A. I believe so. 24 (Defendant's Deposition 25 Exhibit Solutia-Pierle 7 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053361 91 1 mark'd for 2 identification.) 3 BY MS. BOWERS: 4 Q. Mr. Pierle, I ask you to take a look at 5 what's been marked as Solutia-Pierle Exhibit 7. This 6 purports to be a standard record retention schedule. 7 Section 1 of the Records Management Manual of 8 Monsanto. Do you believe that's what this document 9 is? 10 A. Yes. 11 Q. It says on the title page, "Section 1." 12 Were there other sections to the Records Management 13 Manual, other than what we have here? 14 A. I don't, I don't recall there being anything 15 more than that. 16 Q. Okay, so Section 1 was all that there was? 17 A. I believe so. 18 Q. Would you, please, flip to Bates stamp page 19 499? And specifically, I'm looking at item number 10. 20 What does the total retention time designation "While 21 useful only" mean? 22 A. I think you asked me that similar question 23 earlier, and I'm not certain. 24 Q. Would a destroy, or discard or destroy order 25 go out when someone determined that "while useful Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053362 92 1 only" had come to pass? 2 A. Again, I think that was a designation in 3 this case again within, to the--within the Law 4 Department, and that determination would have been 5 useful to, to that individual. 6 Q. Okay, but would the Law Department then 7 subsequently follow up with a discard or destroy 8 order? 9 A. I never saw anything like that. 10 Q. If you would turn to Bates stamp page 507, 11 please, and specifically item number 7, in my review 12 of the documents to prepare for this deposition today, 13 this is the first reference I've come across to 14 pollution and environmental control. Are you aware of 15 any pollution and environmental control document 16 retention policies that would have been in place prior 17 to February of 1972? 18 A. No. There--you recall that in your prior 19 question, there was some reference in the 1970 20 document in this area, I think the terminology that 21 was similar to this, so --so maybe in '70, there were 22 some precursor requirements in this area. 23 Q. Between the years 1970 and 1972, had a new 24 department, or division, or office within Monsanto 25 been created to address environmental control issues? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053363 93 1 A. No. 2 Q. Was a new position added for someone within 3 the company that would--whose job responsibilities 4 would primarily be with respect to environmental 5 matters ? 6 A. In the '70 to '72 time frame? 7 Q. Or anytime thereabouts. 8 A. I don't recall any. 9 Q. What was the first time that Monsanto had a 10 position within the company position, department, or 11 division that was primarily responsible for 12 environmental issues? 13 A. Excuse me. Again, in the, in the Fifties, 14 in the sort of the Central Health Department, there 15 were a couple of individuals who spent some of their 16 time on environmental matters, as I recall it, 17 primarily, air and watering pollution but only as a 18 portion of their, their, their responsibilities. 19 Q. And how did that progress to--I mean was the 20 ultimate conclusion the creation of the Department of 21 Environmental Safety and Health, or-- 22 A. Yeah, in the--it, it, it--the management 23 evolved sort of with external matters, and in, I 24 believe it was '76 or '77, there was a more formal 25 creation of, really, a larger medical health, medical Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053364 94 1 and health department, and that group began to grow 2 over time to deal with medical and health matters. 3 Q. What was the impetus in '76 or '77 to create 4 this new department? 5 A. The--I think it was the volume of and the 6 sophistication of governmental matters beyond the 7 state level, primarily with the creation of EPA in 8 1972 and the addition of additional federal laws, 9 created an external sort of governmental set of 10 entities that had to be dealt with that were beyond 11 what the plants had been dealing with primarily within 12 their own state boundaries, and that, as much as 13 anything I think drove the management to create a, or 14 expand a small, existing unit to spend more time and 15 put more people on these matters. 16 Q. Okay. Well, as that department was growing 17 within the, the corporate-level structure, was there 18 also a similar development and progression, if you 19 will, at the plant level? 20 A. The plants, I think in general, you would 21 say the plant staffs tended to grow that dealt with 22 these particular matters, again as the volume of 23 reading state regulations, and state requirements, and 24 increased numbers of permits grew, that it took more 25 resources at the plant level to deal with those, yes. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053365 95 1 Q. And specifically, at the Anniston Plant, was 2 a new department, or division, or organizational 3 structure, created to deal with these growing 4 regulations and things like that? 5 A. I think at Anniston, it was there was--there 6 were--it's a small plant, so there aren't many people 7 there, there were never many people there, so they had 8 somebody paying attention to environmental matters in 9 a full job capacity going back into the Sixties, as I 10 recall, and I think that group may have grown a 11 little, but it didn't, it didn't grow a lot. 12 Q. Starting in the 1960's at Anniston, who was 13 that person that was responsible for monitoring this? 14 A. I don't, I don't recall his particular name. 15 Q. Okay. At any time, do you remember that 16 person's name, the person or individual that would 17 have been responsible for these matters? 18 A. The first name I kind of remember was an 19 individual, Jerry Brown, who was--had that, had that 20 role. 21 Q. And approximately what time frame are we 22 talking? 23 A. Well, he's--he was at the plant a long time, 24 but I think it began in the Seventies. It could have 25 been before that. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053366 96 1 Q. Other than Mr. Brown, do you remember any 2 names at the Anniston Plant? 3 A. Um, they don't jump, jump to my mind. 4 Q. Do you know if there would be any documents 5 anywhere that would reflect the names of these 6 individuals that served in that capacity at the 7 Anniston Plant? 8 A. I think to the extent that you have been 9 provided organizational charts including the Anniston 10 Plant, that it's probable that it shows up on those 11 documents. 12 Q. In reviewing those charts, what title or 13 position name should I be looking for to find the 14 names of those individuals? 15 A. Well, it's a pretty small plant, and I think 16 if you look under, probably in the staff department 17 areas, you'll see something with an environmental or a 18 pollution control title, something like that, on a 19 box. 20 Q. Okay, so environmental, pollution. Any 21 other description? 22 A. That should get it. 23 (Defendant's Deposition 24 Exhibit Solutia-Pierle 8 25 mark'd for Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053367 97 1 identification.) 2 BY MS. BOWERS: 3 Q. My co-counsel is trying to rush me over 4 here. Mr. Pierle, I'd like you to take a look at 5 what's been marked as Solutia-Pierle Exhibit 8. This 6 purports to be a standard record retention schedule 7 for Monsanto for the--dated April 1974. Do you 8 believe that's what this document is? 9 A. Yes. 10 Q. I don't have any specific questions about 11 this document. 12 (Defendant's Deposition 13 Exhibit Solutia-Pierle 9 14 mark'd for 15 identification.) 16 BY MS. BOWERS: 17 Q. And again, this--Mr. Pierle, I'd like you to 18 take a look at what's been marked as Solutia-Pierle 19 Exhibit 9, purports to be a Records Management Manual 20 for Monsanto Company dated April 1976. Do you believe 21 that's what this document is? 22 A. Yes. 23 Q. I don't have any specific questions about 24 it. 25 (Defendant's Deposition Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053368 98 1 Exhibit Solutia-Pierle 2 10 mark'd for 3 identification.) 4 BY MS. BOWERS: 5 Q. Mr. Pierle, would you please take a look at 6 what's been marked as Solutia-Pierle Exhibit 10, 7 purports to be a Records Management Manual of Monsanto 8 dated May 1978. Do you believe that's what this 9 document is? 10 A. Yes. 11 Q. Would you, please, turn to Bates stamp page 12 666? What is the Department of Medical and 13 Environmental Health? 14 A. This is the department that I previously 15 described that was expanded in the '7 6-'77 time frame. 16 Q. Do you know who was the first head of that 17 department? 18 A. I think at the time, at this time, it was a 19 Dr. George Rausch. 20 Q. Do you know if Mr.--Dr. Rausch is still 21 living? 22 A. He is not. 23 Q. Was there someone that held that position 24 prior to Mr. Rausch--Dr. Rausch holding it? 25 A. I believe that was Dr. Emmet Kelly that had Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053369 99 1 it in the smaller form and version. 2 Q. Who did Drs. Kelly and Rausch report to 3 while in their--in the role of Director of Medical and 4 Health--Environmental Health Department? 5 A. I'm not certain on Dr. Kelly. Dr. Rausch 6 reported to Monte Throdahl, who I've previously 7 mentioned. 8 Q. And I'm sorry, remind me again what his 9 position was. 10 A. He was a senior vice president for the 11 company. 12 Q. This was the first indication or mention of 13 industrial hygiene that I found. Was a separate 14 department or division of the Department of Medicine 15 and Environmental Health devoted to industrial 16 hygiene, was that something new in 1978? 17 A. No. 18 Q. When did that start? 19 A. Well, I think again, industrial hygiene 20 existed as a--you are asking at the company level? 21 Q. Company and plant level. We can start with 22 company first. 23 A. Well, that function was part of Dr. Kelly's 24 organization back in into the Fifties. 25 Q. Okay, and at the plant level? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053370 100 1 A. Um, industrial hygiene was typically--it 2 existed at the plant level, with somebody having 3 safety and industrial hygiene responsibilities for. 4 Q. With respect to the Anniston Plant, do you 5 remember the names of any individuals from, say, 1960 6 through 1980 that would have had responsibilities for 7 industrial hygiene matters? 8 A. I do not. 9 Q. Do you know if there are any documents that 10 would reflect the names of those individuals? 11 A. Again, at the Anniston Plant, being so 12 small, they may not have had a full-time person 13 dealing with this, so it would have typically been in 14 the environment--environmental or safety, health 15 functions and boxes on the charts. 16 Q. Have the industrial hygiene responsibilities 17 always been within the medical Environmental Health 18 Department and its precursors, both at the plant and 19 at the corporate level? 20 A. Yeah, mm-hmm, yes. 21 Q. So those two departments developed together? 22 A. Well, again, I'm not -- you are con--I'm not 23 certain on the, the question. 24 Q. I'm not trying to ask a trick question. 25 A. The responsibilities for hygiene, safety, Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053371 101 1 and environment were typically kind of in the same 2 area at the plants. 3 Q. I'm just trying to determine if they 4 developed as separate departments and then became 5 merged together or if they developed at the same time, 6 kind of parallel to each other. 7 A. Well, they've always been key considerations 8 within the company and especially at the plant 9 operational level, so that's what's giving me--you 10 know, they were kind of--there was always somebody 11 there paying attention to it, watching it. They 12 evolved in terms of if you want to say growth of those 13 based on need at, at the plant sites, which would have 14 been different. 15 Q. Can you recall the names of any individuals 16 that would have been responsible for the evolution of 17 industrial hygiene in environmental matters other than 18 the names of those individuals we discussed that were 19 the head of the Department of Environmental Health and 20 Safety Department? 21 A. No. 22 Q. Any other key personnel that would have been 23 involved? 24 A. Back at this time? 25 Q. From any point 1960 and later. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053372 102 1 A. Well, the key guy that kind of grew in some 2 of these particular areas was an individual by the 3 name of Jack Garrett, who was at the corporate level, 4 but, but again, the, the plants had people that were 5 dealing with this, and I don't recall specific to 6 Anniston who may have had sort of this as part of 7 their responsibilities. 8 Q. Would Mr. Garrett have interfaced with 9 anyone at Anniston on these matters? 10 A. Very possibly. 11 Q. Do you know if Mr. Garrett is still living? 12 A. He is not. 13 Q. Would you, please, turn to Bates stamp page 14 692? Is this one of the self-certification letters 15 that you referred to earlier when we were talking 16 about who had responsibility for compliance? 17 A. This is the certification letter that was 18 specific to the, what I would call direct reports of 19 the head of the company, as indicated by managing 20 directors, that would have been a business unit head 21 or a corporate staff department, and they were 22 reporting directly these two, the corporate secretary 23 or the head of the Law Department. 24 Q. Okay, so these forms would be returned to 25 someone in the Law Department? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053373 103 1 A. The corporate secretary. 2 Q. And the corporate secretary was generally 3 the general counsel? 4 A. Yes. 5 (Defendant's Deposition 6 Exhibit Solutia-Pierle 7 11 mark'd for 8 identification.) 9 BY MS. BOWERS: 10 Q. Mr. Pierle, I'd ask you to take a look at 11 what's been marked as Solutia-Pierle Exhibit 11. This 12 purports to be a Records Management Manual of Monsanto 13 Company dated April 1994. Do you believe that that's 14 what this is? 15 A. Yes. 16 Q. Would you, please, flip to Bates stamp page 17 726? With respect to item number 1, "Authorizations 18 for signatures to documents," the retention time is 19 permanent. Where are these documents kept? 20 A. I'm not, I'm notcertain. 21 Q. Do you believe-22 A. Uh, probably at the point of origination. 23 Q. Plant level? 24 A. Um, again, that, that could, could vary. I 25 think what this refers to, that the federal government Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053374 104 1 began to require, before certain applications could go 2 forward, that they would be signed by a certain level 3 in the company and the laws allowed those signatures 4 to be delegated, and so the delegation may very well 5 have come out of somebody from general offices where 6 that document would have been generated but then 7 received at the plant site and held with the permit 8 application, so I think what this--again, it didn't 9 describe where the document ought to be held, it just 10 said don't get rid of it. 11 Q. Is there a central repository for these type 12 of documents, for-13 A. Not that I'm aware of in terms of the 14 originals. 15 Q. This refers to the environmental law file. 16 What is that? 17 A. Well, environmental law was a part of the 18 Law Department, and it would indicate that, that a 19 copy of that delegation would have been kept in, in 20 the Environmental Law Department. 21 Q. Is there an assistant general counsel or 22 another attorney that's designated as the head of the 23 Environmental Law Department? 24 A. There, there typically was someone that was 25 that person. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053375 105 1 Q. And who would that person have been--well, 2 let me ask it this way. What was the first point in 3 time that there was someone within the Law Department 4 that was primarily responsible for environmental 5 issues? 6 A. Again, probably in the Sixties. 7 Q. What would that--do you know specifically 8 who that person would have been in the Sixties? 9 A. The first person I recall--and again, I 10 think again, the environmental law grew as from 11 probably a part-time to full-time but was an 12 individual by the name of Mr. Park. 13 Q. Do you know if Mr. Park was an attorney? 14 A. Yes. 15 Q. Okay, and subsequent to Mr. Park, who in the 16 Law Department maintained those responsibilities for 17 environmental law? 18 A. Mr. Gilhousen. 19 Q. And after Mr. Gilhousen? 20 A. I don't recall the--after the split who the 21 Monsanto lawyer person was or who does that today. 22 Q. Okay. With respect to item number 3, 23 "Regulatory agencies, federal, state, country, 24 municipal," looking under section A, "Company copy of 25 noncompliance and other records supporting data and Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053376 106 1 originating office file," and the retention time on 2 that is permanent, do you know where records 3 reflecting noncompliance would, would be kept? 4 A. Well, again, an originating office file, I 5 would think again those would be predominantly at the 6 plant location sites. 7 Q. So if some sort of noncompliance order or 8 report went out, the plant that was in noncompliance 9 would be responsible for keeping records related to 10 that noncompliance? 11 A. Yes. I mean, I, I'm sure there were copies 12 in the Law Department, but-13 Q. Would, would a copy also be sent to the 14 Department of Environmental Safety and Health? 15 A. Um, may have been, but not necessarily. 16 Q. Was there a formal procedure in place for 17 any noncompliance reports to be sent? 18 A. I think that was, that was principally Law 19 Department activity. 20 Q. Was there a procedure where someone within 21 the department, the Central Department of 22 Environmental Safety and Health would be notified if 23 there was a noncompliance issue at one of the plants 24 or facilities? 25 A. I think the notification expectation was Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053377 107 1 predominantly to the Law Department. Others may have 2 been made aware, but, but the documentation around 3 that would have been principally to the Law 4 Department. 5 Q. And on the next page, Bates stamp 727, 6 looking at Item number 4, which refers to surveys and 7 audits, does item number 4, does that relate to 8 environmental audits? 9 A. I believe it does, yes. 10 Q. Who would conduct environmental audits 11 within Monsanto and Solutia? 12 MR. NASSIF:: You mean for the Anniston 13 facility? 14 MS. BOWERS:: Yes. 15 MR. NASSIF:: Okay. 16 A. These were typically done by-'-it changed 17 over time. They were, they were done at one time by 18 a, a collection of people, maybe, from the business 19 unit that had responsibility for a certain group of 20 plants. I think at one time, these were done by--the 21 environmental audits were primarily done within the 22 business units and by an audit entity, and then at a 23 time in the Eighties or Nineties, we actually had a 24 group of people in the business units doing these, so 25 it changed over time. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053378 108 1 Q. Are there people within the corporate 2 structure that do audits on a full-time basis? 3 A. Today? 4 Q. Yes. 5 A. I'm not certain today. There was at the 6 time when I, when I retired. 7 Q. There was? 8 A. Yes. 9 Q. And how long had that been the case, that 10 there were people that did this full-time? 11 A. I'm not certain. 12 Q. Is there a central repository where 13 environmental audits are kept or records reflecting 14 environmental audits are kept? 15 A. To the extent that they were done by this 16 group which came into existence sometime in the late 17 Eighties, in part, they would have been kept within 18 those, and they were typically within the operating 19 companies' environmental health and safety staff 20 groups. 21 Q. So if the Anniston facility got audited, 22 where would those records be reflecting that audit? 23 And when I ask that question, I'm asking at all points 24 in time that audits were conducted. 25 A. Well, we began a more formal auditing Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053379 109 1 practice in the early Eighties, and they would have 2 been maintained initially probably within the Ag, 3 Agricultural business unit, Agricultural Chemicals 4 business unit, and later in the Eighties, within the 5 chemical company's environmental health and Safety 6 Group. 7 Q. So geographically, the records would be in 8 St. Louis? 9 A. They--probably. They would, they would 10 exist at the plant site because it was basically a 11 program intended to provide a service to the plant 12 location, so the recipient of the audit, itself, was 13 the, was the plant. 14 Q. Would you, please, turn to Bates stamp page 15 749? And specifically item C, "Environmental 16 documents," what was the first point in time that 17 Monsanto or Solutia created a separate document 18 retention policy with respect to environmental 19 documents ? 20 A. The, the document retention policies, all 21 that we've talked, would have addressed, you know, 22 environmental matters from the beginning. I think 23 what these documents reflect is as there became more 24 and more documents, there was more and more 25 specificity within the records, the updates of the Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053380 110 1 records manual, so I think the policies covered 2 environmental documentation from the beginning of the 3 manuals. It just got more specific, and as 4 governmental requirements changed on retention times, 5 then that guidance was included, so it was more an 6 increase of specificity, as opposed to with an 7 originating period. 8 Q. What was the first year that environmental 9 documents became a separate category within the larger 10 document retention policy? 11 A. I'd have to go back and, and look at these 12 documents to answer that specifically. I don't 13 recall. 14 Q. Do you have an approximate time frame? 15 A. No. 16 Q. Under Item number 1, the retention time for 17 the first bullet point, first and second bullet 18 points, item number 1, "The retention time is 19 permanent if required by law to be submitted to the 20 government or if required by law to be retained by the 21 company to show compliance with federal regulations," 22 where would these documents be kept? 23 A. Wherever the point of compliance would be. 24 Q. So that would be at the facility plant 25 level? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053381 Ill 1 A. Typically, yes. 2 Q. And who at the facility or plant would be 3 responsible for ensuring that those records were kept 4 in compliance with the law? 5 A. Probably the individuals who were preparing 6 the, the documents that needed to be submitted. 7 Q. Do you know the names of those individuals 8 with respect to the Anniston Plant? 9 A. Not, not beyond what I've given you. 10 MS. BOWERS: Do two more and take a break 11 sound good? 12 (Defendant's Deposition 13 Exhibit Solutia-Pierle 14 12 mark'd for 15 identification.) 16 BY MS. BOWERS: 17 Q. Mr. Pierle, I'd ask you to take a look at 18 what's been marked as Solutia-Pierle Exhibit 12. This 19 purports to be a document--excuse me, a records 20 retention policy for Monsanto Company dated May 23rd, 21 2001. Do you believe that that's what this document 22 is? 23 A. Yes, recognizing this is a different 24 Monsanto Company than we've been talking about. 25 Q. Okay. Well, explain that to me, if you Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053382 112 1 will. Would this document--well, explain to me, if 2 you will, what you mean by that statement. 3 A. Well, we've been using "Monsanto Company," 4 and it was one company with a lot of businesses, and 5 now this is, this is a different company. 6 Q. Okay. This document, would it apply to 7 Solutia or Pharmacia? 8 A. I, I don't believe so. 9 Q. Have you ever reviewed this document before? 10 A. No, I have not. I have seen it, but I've 11 not read it in depth. 12 Q. Now, I understand that you retired in 1999, 13 but in your capacity as the corporate representative, 14 would this document have applied to the Department of 15 Environmental Health and Safety that you were the vice 16 president of? Would this policy have applied to that 17 department? 18 A. No. 19 Q. Mr. Pierle, are you familiar with the term 20 "Trash Bash Day"? 21 A. I think I kind of have a sense of, of what 22 it is . 23 Q. What is Trash Bash Day? 24 A. Consistent with the certifications that 25 happen typically within a, a defined, sort of Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053383 113 1 generally defined period of time, and part of this 2 file, like cleaning the trash was a day there would 3 just be a lot of trash generated up to this point, and 4 I think it was just more an indication of sort of a 5 physical presence of the file policy or the document 6 policy being adhered to. 7 Q. Was that an annual event? 8 A. Yeah, I believe the certifications were 9 required annually, and therefore, you would typically 10 see a lot of bags of, you know, no-longer-retained 11 documents ready for disposal. 12 Q. Who would organize Trash Bash Day? 13 A. I think it was done generally around the--to 14 be a help and consistent with the directive coming out 15 of the corporate secretary's office to get these 16 certifications done. 17 Q. Would all of the divisions and departments 18 receive a notification from the corporate secretary 19 that the day was coming up? 20 A. Well, the certification didn't have to 21 happen on a particular day. I think this was more 22 around a time period that got to you a point probably 23 close to the expected deadline of getting all this 24 done and was done primarily so the trash collectors 25 would get prepared for, you know, a heavy load of Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053384 114 1 trash collection. 2 Q. Would a disposal company be called in to 3 take away this extra trash, or was there -- 4 A. I, I'm not, I'm not certain of that. A lot 5 of it went into trash bags designated for burning, 6 burn bags, and a lot of the other stuff kind of went 7 into general trash, so -- 8 Q. Do you know who supervised the burning of 9 documents ? 10 A. I do not. 11 Q. Who made the decision what documents would 12 be burned and what documents would just be disposed 13 of? 14 A. I think the general, the general demarcation 15 was the stuff that's not company confidential, trade 16 secret, anything like that that was general 17 literature, so if you had to clear out regulatory 18 files, for example, you know, that could go into a 19 general disposal, but if it contained company 20 confidential trade secret information that was within 21 the purview of being distributed, you didn't want 22 people going through your trash to get that, and that 23 was the--at least one of the principal guides on 24 separating. 25 (Defendant's Deposition Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053385 115 1 Exhibit Solutia-Pierle 2 13 mark'd for 3 identification.) 4 BY MS. BOWERS: 5 Q. Mr. Pierle, I've asked you to take a lock at 6 what we've marked as Solutia-Pierle Exhibit 13. This 7 purports to be Solutia, Inc., Records Retention Manual 8 dated May 2002. Do you believe that's what this 9 document is? 10 A. Yes. 11 Q. Would this document retention policy apply 12 to the company that we've been referring to throughout 13 the day as Monsanto as it now exists, Solutia, Inc.? 14 I'm sorry, I apologize. 15 A. I think this document refers specific to 16 Solutia as it existed on May 2002. 17 Q. 2002: Okay, and that company is the company 18 that we've been referring to earlier in the day as 19 Monsanto? 20 A. No. 21 Q. Is a spinoff of? 22 A. A spinoff of Monsanto. 23 Q. Of Monsanto: Okay. Would you, please, turn 24 to Page Bates stamp page 874? Looking at the third 25 paragraph where it states "The vice president in Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053386 116 1 charge of each business platform or core function must 2 certify in writing to the Office of Corporate 3 Secretary that his or her entire platform or function 4 has reviewed its files and has kept or discarded all 5 documents in accordance with the retention times in 6 this manual." What are, what are business platforms, 7 in a general sense? 8 A. I'm not familiar with that terminology. I 9 think I would read it, there, the business platform is 10 basically what in other documents has been identified 11 as the division or the--basically, it's the 12 organization that is running a particular business. 13 Q. What is a core function? 14 A. That, again, is probably very similar to 15 what we've seen before as corporate department or 16 corporate staff department. I think it's just the 17 only designation, there, is between the line business 18 managers and all of the heads of the staff departments 19 got this note, and each of them are responsible for 20 what's called for, here, on this page. 21 Q. Looking at the next page, Bates stamp 875, 22 item number 4, which addresses when the retention 23 times in this manual do not apply, do you know who 24 currently is the head of the Law Department? 25 A. At Solutia? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053387 117 1 Q. Yes. 2 A. No, I do not. 3 Q. Who was the head of the Law Department when 4 you retired? 5 A. Carl Barnagle (Phonetic). 6 Q. And who was the person within the Law 7 Department that had primarily--primary responsibility 8 for environmental litigation and environmental 9 matters ? 10 A. Mr. Gilhousen. 11 (Defendant's Deposition 12 Exhibit Solutia-Pierle 13 14 mark'd for 14 identification.) 15 BY MS. BOWERS: 16 Q. Mr. Pierle, I'd like you to take a look at 17 what's been marked as Solutia-Pierle Exhibit 14. This 18 purports to be a document retention policy of Monsanto 19 dated--well, date last updated 8/22/02. Do you 20 believe that that's what this document is? 21 A. Yes. 22 Q. Are you familiar with this document? 23 A. I just perused it. 24 Q. Would this document apply to Solutia? 25 A. No. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053388 118 1 Q. Would this document apply to Pharmacia? 2 A. No. 3 MS. BOWERS: Why don't we take a quick 4 break? Go off the record. 5 (Discussion off the 6 record.) 7 (Luncheon recess.) 8 (Defendant's Deposition 9 Exhibit Solutia-Pierle 10 15 mark'd for 11 identification.) 12 BY MS. BOWERS: 13 Q. Mr. Pierle, before we broke for lunch, we 14 were talking about document retention policies within 15 Monsanto and Solutia, and I wanted to ask, just to 16 recap the dates of those policies we looked at, we 17 looked at a policy from October of 1955, one from 18 March of 1967, one from November of 1970, February 19 1972, April 1974, April 1976, and May 1978. To your 20 knowledge, were updates and new policies or updated 21 revised policies issued every two years? 22 A. They were revised, you know, per the 23 revisions that you have, so the answer to that is no. 24 Q. Okay. Were you--were the policies revised 25 annually, then, or -- Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053389 119 1 A. I believe it was at the discretion of the, 2 of the secretary. 3 Q. The corporate secretary? 4 A. Yes . 5 Q. Who would have been the general counsel? 6 A. I believe that's correct. 7 Q. Where is Solutia's corporate headquarters? 8 A. They are in, I believe, what'' s called the 9 Maryville Center out in Town & Country, Missouri. 10 Q. What about Pharmacia? 11 A. I'm not certain on Pharmacia, given 12 that--well, I, I don't know. 13 Q. Do you believe that it's in Missouri? 14 A. I don't know. 15 Q. When did Solutia come into existence? 16 A. In mid 1997 in a spin from Monsanto, or it 17 may have been--'96-'97. I forget the exact time came. 18 Q. It was a spinoff from Monsanto? 19 A. That's correct. 20 Q. Prior to that spinoff, was there a company 21 called Solutia? 22 A. Not to my knowledge. 23 Q. What was the impetus for the spinoff in 24 1997? 25 MR. GILHOUSEN: That's getting to--object to Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053390 120 1 that. I mean, you are getting to what's the corporate 2 structure that we're dealing with here. It's 3 historical. You quoted the dates and what was 4 created, but not what he thinks. 5 MS. BOWERS: Okay. 6 MR. TURNER: I think we can withdraw that 7 question. That's fine. 8 MS. BOWERS: That's fine. 9 BY MS. BOWERS: 10 Q. What were all of the--which departments of 11 Monsanto got spun off into Solutia? 12 A. The--Solutia was basically not a group of 13 departments but a, a group of businesses that were 14 predominantly the--what existed at that time within 15 Monsanto as Monsanto's chemical businesses. 16 Q. And specifically, what were those chemical 17 businesses? 18 A. There was a grouping of fiber and 19 intermediate kind of businesses, and there were two or 20 three others. I don't recall the exact titles of the, 21 of the businesses. 22 Q. Were any of the agricultural divisions of 23 Monsanto spun off into Solutia? 24 A. No. 25 Q. Anything other than the chemical businesses Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053391 121 1 spun off into Solutia? 2 A. I don't believe so. 3 Q. Prior to the spinoff in '97, where was 4 Monsanto's corporate headquarters? 5 A. In St. Louis. 6 Q. In the same physical location as Solutia's 7 corporate headquarters? 8 A. No. 9 Q. So when the spinoff occurred, did a group of 10 people physically get up and move to a new location? 11 A. That, that happened at a later date. The 12 Solutia businesses were basically sort of physically 13 separated into separate buildings within, at that 14 time, what was Monsanto's worldwide headquarters. 15 Q. Where is Solutia's principal place of 16 business? 17 A. What do you mean by that? 18 Q. Where is the primary operation of Solutia? 19 Would there be one place that would be the primary 20 operation? 21 A. No, I think Solutia--I mean, its 22 headquarters are as I described it. I think at the 23 spin, I forget how many plants there were. I think 24 there were 10 or 15, something like that, maybe even 25 more. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053392 122 1 Q. Were they concentrated in one geographic 2 area? 3 A. No. 4 Q. When the spinoff occurred, were, were the 5 assets, the physical property of the Anniston Plant 6 spun off to the new company, to Solutia? 7 A. The, the Anniston Plant was part of the 8 plants that were in the Solutia, Incorporated. I'm 9 just--you said "assets," and I don't know whether, you 10 know, all the assets were at the plant were within, 11 within that company or not. 12 Q. Okay. Did everything at Monsanto's Anniston 13 Plant become the property of Solutia when the spinoff 14 occurred? 15 A. I'm not certain of that. 16 Q. Would all of the employees at the Anniston 17 Plant have become Solutia employees on the date of the 18 spinoff? 19 A. I'm not certain. 20 Q. Is Solutia a publicly traded corporation?!? 21 THE WITNESS: What's the answer? 22 BY MS. BOWERS: 23 Q. If you don't know, that's-24 MR. GILHOUSEN: Before the bankruptcy, you 25 can answer. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053393 123 1 THE WITNESS: Yeah, before the bankruptcy. 2 Yes . 3 (Laughter.) 4 BY MS. BOWERS: 5 Q. Okay. 6 A. You can still trade the stock today, yes. 7 MR. GILHOUSEN: It's over-the-counter. 8 MS. BOWERS: I could get some if I really 9 want it? Fair enough. 10 BY MS. BOWERS: 11 Q. Is Pharmacia publicly traded? 12 A. Today, I don't believe so. 13 Q. At some point, was it? 14 A. Yes. 15 Q. How about prior to the spinoff in '97, was 16 Monsanto publicly traded? 17 A. Yes. 18 Q. Describe, if you would, starting with the, 19 the board of directors--in '97, as of the date of the 20 split, describe, if you would, starting with the, the 21 board of directors, what was the, the general 22 structure of Solutia? Was there a CEO that reported 23 to the board of directors? 24 A. Yeah, there was a board of directors and a 25 CEO that reported, I believe we had a president that Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053394 124 1 reported to the CEO, and then it was a fairly flat 2 organizational structure of on the order of some ten 3 business unit heads and a handful, five to six, I 4 guess, of staff department functions that reported to 5 the president or the CEO. 6 Q. When you say "flat structure," what do you 7 mean by that? 8 A. Well, as I said, ten business units and a 9 lot--so there were 15 or 16 people, as opposed to what 10 I'd call a hierarchical that may have only had three 11 to five people reporting to the CEO at that time. 12 Q. Was that flat structure a change from the 13 way things had been under Monsanto? 14 A. The organization structure sort of changed 15 from time to time, so there had been in Monsanto, you 16 know, both a flat structure and in prior years, maybe 17 more, a more hierarchical structure. It just changed 18 over time. 19 Q. In '97, at the split, who was the CEO of 20 Solutia? 21 A. At the time of the spin? 22 Q. At the time of the spin. 23 A. Robert Potter. 24 Q. Do you know how long he served as CEO? 25 A. I believe Bob retired in 1999 or 2000. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053395 125 1 Q. Do you know the names of any of the 2 directors or heads of the business units that would 3 have reported directly to Mr. Potter in '97? 4 A. Well, as I recall, the business unit heads 5 reported to John Hunter at that time. 6 Q. Who was Mr. Hunter? 7 A. He was the president. 8 Q. Who reported to Mr. Potter? 9 A. I believe Mr. Hunter, and there was a senior 10 vice president, Mike Miller, and the general counsel, 11 Carl Barnagle, and there may have been one or two 12 others. I'm not certain. 13 Q. At the time of the spin, what were the major 14 divisions or departments of Solutia? 15 A. As I was trying to indicate, there were, 16 there were ten business units, and I, I think I 17 mentioned fibers or intermediates was one of them. I 18 just don't recall all the rest of the, the names of 19 those ten sectors. 20 Q. Did each of these ten business units operate 21 more or less within themselves? Was there a lot of 22 cross-pollination of personnel between and among the 23 business units? 24 A. The business units had financial 25 responsibility for their areas and their product Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053396 126 1 sectors, and typically, they had a number of people 2 that were assigned to those business areas. At the 3 same time, there were the staff departments that kind 4 of worked for all the businesses, depending upon what 5 kind of staff services they required. 6 Q. In working down this, this business 7 structure, where would be the first point of contact 8 that someone on this, this structure would have with 9 the plants or the facilities? 10 A. Supervisory responsibility? 11 Q. Yes. 12 A. Typically, within--well, there was a, there 13 was an individual who was really the head of all the 14 manufacturing function and had the plant people all 15 report to him. 16 Q. So all the plant people reported to one 17 particular individual? 18 A. Yes. 19 Q. And that--what was that individual's title? 20 A. Probably Vice President of Manufacturing or 21 something similar to that. 22 Q. Same question within Monsanto prior to the 23 spin: Would the Vice President of Manufacturing have 24 been the first direct supervisory contact with the 25 plants or facilities? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053397 127 1 A. No, the organization was different, as I 2 recall, and in the various business units, there was 3 probably a Director of Manufacturing in each of the 4 business units as to which the plants would report. 5 Q. So it sounds like there was even one more 6 step between the CEO and the plants under the Monsanto 7 system? 8 A. I think that's a fair characterization. 9 Q. Okay. For this next set of questions, I 10 want to clarify that I'm inquiring as to Monsanto 11 prior to the spin, and we can work through the 12 timeline to how it came to be with Solutia. Within 13 Monsanto, which department or division had the primary 14 responsibility for compliance with State, federal, and 15 local environmental laws and regulations? 16 A. Again, it would have been at the plant 17 level. 18 Q. So within the business units, themselves? 19 A. Yeah. I mean, each, pretty much each of the 20 business units had plants within those organizations. 21 Q. So would the business units, themselves, 22 have someone or some group of people that were 23 responsible for this--for environmental 24 responsibilities, compliance responsibilities, or 25 would each plant? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053398 128 1 A. Well, the plants would have the, the 2 principal, the fundamental responsibility was at the 3 plant. 4 Q. But would the business units, themselves, 5 also have someone with those responsibilities? 6 A. No. 7 Q. Did that ever change? 8 A. No, I'm--you know, I'm--every, every plant 9 reported to somebody, but the fundamental 10 responsibility for compliance was at the plant level. 11 Q. Do you recall the, the year, or an 12 approximate year when a formal environmental audit 13 program was instituted? 14 A. It was around 1980. 15 Q. And at what level would that--at what point 16 on the organizational chart would that formal 17 environmental audit program have fit into? 18 A. It--again, it was a program that was 19 basically, it was probably managed at the 20 environmental staff level in what was called the 21 operating company, but the people that were utilized 22 at that time were from, predominantly from the plants. 23 It was sort of a cross-compliance audit groups were 24 put in place. 25 Q. What's an operating company? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053399 129 1 A. An operating company is--it was probably an 2 aggregation of business units. 3 Q. Did these companies have separate names? 4 A. When they existed, they did. They didn't 5 exist all the time. 6 Q. Would they be separately incorporated 7 companies ? 8 A. These were, these were not legal entities. 9 They were internal organizational devices for managing 10 the businesses. 11 Q. Okay, what were some of the names of these 12 operating companies? 13 A. The Chemical Group, the Ag Chemical Group, 14 at one time, I guess, Searle, in the pharmaceutical, 15 was an operating unit. They were basically like the 16 Chemical Group or, you know, a unit of Monsanto 17 Company is kind of how they were, they were described. 18 Q. Was there any formal procedure for forming 19 one of these operating companies? 20 A. The internal organization was always sort of 21 at the, at the direction of the CEO or the 22 CEO/president. 23 Q. So the formation of an operating company 24 would come from the CEO down? 25 A. Yeah. Again, it's an organizational Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053400 130 1 designation as opposed to a, an entity, a legal entity 2 designation. 3 Q. Does Monsanto or Solutia have a formal 4 groundwater monitoring department or audit program? 5 A. Again, the, the work on groundwater was done 6 within the same structure predominantly at the plant 7 sites with the assistance and, sometimes, coordination 8 of the environmental people that existed at the, at 9 the, the staff levels within these designated business 10 units. 11 Q. With respect to the, the formal 12 environmental audit procedure, we talked earlier about 13 there are people within the company who do this on a 14 full-time basis. Where do those people get the money? 15 Whose budget are they in? 16 A. I think I indicated part-time--there were 17 full-time people; part-time, there weren't. 18 Q. Right. 19 A. When there were full-time people, it 20 basically was in the budget of that, whatever staff 21 department they resided in would be in a staff cost 22 center budget. 23 Q. So there was--was there a separate line item 24 in the budget for environmental audits? 25 A. To the extent that a period of time when Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053401 131 1 they did, there would have been a, a, probably a subs 2 cost center budget that dealt with, with that group. 3 Q. Which department within Solutia now is 4 responsible for conducting environmental audits? 5 A. I'm, I'm not certain today what Solutia is 6 doing with respect to audits. 7 Q. Prior to your retirement, what department 8 had that responsibility? 9 A. That was within my department. 10 Q. Was there a, an individual or a person with 11 a particular job title who was responsible for 12 conducting these audits? 13 A. I think there was a small group of--I forget 14 the exact number that were doing audits, and I'm not 15 certain we had a designated leader, because at that 16 time, we were trying to do self-managed groups, and 17 these were all competent people, so I don't think 18 there was an individual that, that I recall 19 supervising that whole group. 20 Q. Was there a name associated with that group? 21 A. It, it was probably the Environmental Audit 22 Group. 23 Q. And who did the Environmental Audit Group 24 report to? 25 A. I should recall. I believe, they reported Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053402 132 1 at that time to Garth Forte. 2 Q. What was his title? 3 A. I'm not certain. 4 Q. Was he a direct report to you when you 5 were -- 6 A. Yes. 7 Q. --the VP? 8 A. Yes. 9 Q. So the Environmental Audit Group would have 10 been two steps down the organizational chart from you? 11 A. I believe that's correct. 12 Q. Approximately, how many people are we 13 talking about that would have been the Environmental 14 Audit Group? 15 A. I believe at that time, there were three or 16 four. 17 Q. Is there someone within Monsanto, now with 18 Solutia, that had the title "Environmental Manager" or 19 something close to that? 20 A. Well, over time, there were several people. 21 That was a kind of a common title that was used. 22 Q. What, what responsibilities do you associate 23 with that title? 24 MR. GILHOUSEN: Is this for Monsanto now or 25 Solutia. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053403 133 1 MS. BOWERS: Let's start with Monsanto? 2 A. Those, those positions were generally a role 3 of coordination, guidance, regulatory expertise. 4 BY MS. BOWERS: 5 Q. Coordination of what? 6 A. Activities that went on at probably more 7 than one plant as it dealt with their work to meet 8 regulatory requirements, as well as internal company 9 policies. 10 Q. Where would the environmental manager fit in 11 with respect to--well, first question, which 12 department or division would the environmental manager 13 be in? 14 A. Most of the time, they reported into the, 15 the staff environmental health and safety function. 16 Q. Okay, and how far up or down the 17 organization of that particular department would the 18 environmental manager be? 19 A. They would typically report to the head of 20 that unit. 21 Q. Would that department have their own 22 operating budget? 23 A. Yes. 24 Q. Is there a separate environmental 25 procurement department? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053404 1 A. No. 134 2 Q. Or was there? 3 A. No. 4 Q. Okay, same line of questions with respect to 5 Solutia now: Is there an environmental manager within 6 Solutia now? 7 A. I believe there, there is. 8 Q. And what job responsibilities do you 9 associate with that title? 10 A. I'm not certain of that today. That 11 function is headed up by a vice president of, of ESH, 12 but I'm not up-to-date on the specifics of the, the 13 people or the job titles within, within his group. 14 Q. At the time that you retired, what job 15 responsibilities did you associate with the 16 environmental manager? 17 A. I think those that I described earlier. 18 Q. And that person would have reported directly 19 to you? 20 A. Um, probably. 21 Q. Did the Anniston Plant have a budget for 22 environmental compliance issues that was separate and 23 distinct from the Environmental Safety and Health 24 Department on the corporate side of things? 25 A. Yes. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto WATER PCB-SD0000053405 135 1 Q. And how would that money be budgeted to the 2 Anniston Plant? 3 A. Um-- 4 MR. GILHOUSEN: Objection. In the process 5 of how it was budgeted, as opposed to is there a-- 6 MS. BOWERS: Let me clarify. 7 BY MS. BOWERS: 8 Q. How would, how would the Anniston Plant 9 interact with whoever they needed to interact with at 10 the corporate level to obtain that money? I'm merely 11 trying to-- 12 A. The--let me see if this helps you. 13 Q. Okay. 14 A. The budgets at that time that the plant came 15 out--that was a plant budgeting process, so that was 16 all done there. It was not connected directly to the 17 budgeting process with the, the, the staff or the 18 company staff environmental groups, so those were 19 typically not connected. 20 Q. Okay. 21 A. Okay? It was connected, theirs was 22 connected to the plant budget. This budget at the 23 company staff level, let's say, was connected to 24 company budgeting processes. Obviously, at some point 25 in time, they all came together, but they were not--in Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053406 136 1 other words, the, the staff or the environmental was 2 not budgeting the, the plant or direct control over 3 the plant budget. 4 Q. That's what I'm looking for. Thank you. 5 Within, within the Department of Environment, Safety 6 and Health, are compliance issues budgeted by media, 7 air, water, and soil? 8 A. Not typically, no. 9 Q. Are there any in-house attorneys at old 10 Monsanto or Solutia now who worked solely with 11 environmental compliance issues? 12 A. Those types of issues fell to the 13 environmental attorney to, to deal with. 14 Q. Anybody within the Department of 15 Environment, Health and Safety, or all those attorneys 16 in the Law Department? 17 A. Well, the attorneys were in the Law 18 Department. 19 Q. Okay. Did your department have any 20 attorneys that were under your department? 21 A. No. 22 Q. When Monsanto would receive a notice of 23 violation of an environmental regulation, in what 24 physical location would those notices be kept? 25 A. Okay, I think we talked a little bit about Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053407 137 1 this before. The compliance notices would probably be 2 held at the point of receipt or at the point of 3 alleged noncompliance. That's where they would be 4 held. Copies would be also available in the Law 5 Department. You know, there may have been copies made 6 and circulated, but those were the two principal 7 points where notification and action was expected. 8 Q. Did either Monsanto or does Solutia now 9 prepare an annual environmental report? 10 A. We did prepare environmental reports 11 beginning sometime in the Eighties, I believe, and 12 they were prepared up through my time of retirement, 13 and I believe that both companies are still preparing 14 some sort of public report today. 15 Q. Who is responsible for preparing those 16 reports ? 17 A. Those were --I guess the coordination on 18 those was usually within the public relations segment 19 of the company. 20 Q. Would the Department of Environment, Health 21 and Safety work on developing those reports, as well? 22 A. Yeah, we, we would both, I guess, 23 participate some content and also participate in the 24 review. 25 Q. Are copies of those reports maintained? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053408 138 1 A. That, I don't know. They were all--those 2 were all public reports, so they, you know, they ought 3 to be available, I guess, through general public, but 4 I don't know whether they are, you know, they've kept 5 historical copies of those or not. 6 Q. Where are Solutia's environmental permits 7 kept? 8 A. Again, permits as they would deal with 9 operational aspects and permits, they would be kept at 10 the plant sites. 11 Q. Is the answer the same with respect to old 12 Monsanto? 13 A. Yes. 14 Q. Would there be one person at the Anniston 15 Plant that would be responsible for maintaining all of 16 those permits? 17 A. There's probably one person that, that, you 18 know, knows, knows what they are, and where they are, 19 and, and that sort of thing. 20 Q. Who would that person be? 21 A. Um, I, I believe it's probably whoever their 22 environmental coordinator is, and I'd have to go to an 23 organization chart to get the current person. 24 Q. Do you remember the name of anyone that was 25 that person at the Anniston Plant at any time? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053409 139 1 A. Well, I believe the last guy I remember was 2 a gentleman, I think his last name was Jones. 3 Q. Do you remember anyone else besides 4 Mr. Jones that would have had that responsibility at 5 the Anniston Plant? 6 A. I mean, I guess Jerry--I apologize 7 for--Jerry Brown would have had that for awhile, and 8 whoever their kind of successors were, I just don't 9 recall their names in between those time periods. 10 Q. Does either Monsanto or Solutia have a 11 written environmental policy? 12 A. We, we, we had a set of policies and 13 guidelines when I retired, and I believe that both 14 companies still have something in place that, that 15 would be described as that, yes. 16 Q. When were those policies first developed 17 within Monsanto? 18 A. I believe the--I guess what we would call 19 the documents were prepared in the mid Seventies with 20 the creation of this corporate or this expansion of 21 this small department into a more corporate function 22 of safety and--or, I'm sorry, health and environment 23 within Monsanto. There was at that time produced a 24 sort of a specific set of Monsanto policies and, and 25 guidelines. I think there were some more generic Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053410 140 1 statements prior that would include--would have 2 included, you know, aspects of general compliance, but 3 specific to environment and more specific, those were, 4 I think, adopted in '76, 1977 time period. 5 Q. Do you know if there are still copies of 6 these policies somewhere? Is there a repository where 7 they are kept? 8 A. I have seen those, I guess, in some other 9 depositions that are now contained or held by the 10 lawyers. Where else they might be, I'm not certain. 11 Q. Do you know if anyone has made an effort to 12 look for them in connection with this litigation? 13 A. I do not. 14 Q. Other than these environmental policies, are 15 there any documents within Monsanto or Solutia that 16 would reflect other self-regulation with respect to 17 the environment? 18 A. I think these annual reports we talked about 19 contained much of that information. 20 Q. Is there an environmental policy and 21 procedures manual? 22 A. Without holding me specific to that as its 23 title, there is a, there is a document that includes 24 policies. 25 Q. What type of information is in that Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053411 141 1 document? 2 A. Well, they were--they're basically intended 3 mainly to focus on internal programs or policies to 4 guide internal programs with respect to certain 5 categorical areas, and again over time, we call these 6 the worldwide environmental guidelines, kind of a 7 generic name, and they were periodically revised, and 8 the subject matter or the policy matter in them 9 changed over time as, as to reflect sort of current, 10 you know, public policy expectations. 11 Q. Do you know what year these worldwide 12 environmental guidelines would have been started to be 13 kept? 14 A. I think that was my reference to the '16-'77 15 time period. 16 Q. Do you know if there are still copies of 17 them in existence? 18 A. I think we just talked about that. 19 Q. I apologize if I'm being repetitive. Do you 20 know where those copies would be? 21 A. No, as I said, other than knowing that the 22 lawyers have--I've seen those in preparation for other 23 litigation, I'm not certain. 24 Q. Did Monsanto, or has Solutia ever hired 25 outside environmental consultants? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053412 142 1 A. Yes. 2 Q. What was the first point in time you know of 3 outside environmental consultants being hired? 4 A. I, I don't, I don't know. 5 Q. 197 0's ? 6 A. I'm sure they were used long before that. 7 Q. Okay. What sort of things would outside 8 environmental consultants be used for? 9 A. They were probably used for understanding 10 regulations, specific technical support, you know, 11 assistance in meeting government requirements. 12 Q. Who would have the authority to hire these 13 consultants ? 14 A. I think any, anybody that had a need and had 15 the, the budget monies available to do so. 16 Q. Who would have control over budget money to 17 be able to do that? Would that be a vice president 18 type, or-- 19 A. Budgets were strictly--or were, were, were 20 typically controlled by your next level of, of 21 supervision. 22 Q. Was there any sort of procedure that had to 23 be followed within the corporate structure for getting 24 approval of hiring an outside consultant? 25 MR. GILHOUSEN: We're going to outside the Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053413 143 1 organizational structure into decisions on who hires 2 what on budgets. I can understand the question as to 3 were consultants hired, but the process in that is a 4 little -- 5 MS. BOWERS: I'm just trying to determine 6 who had the authority to hire. 7 MR. GILHOUSEN: Okay. 8 A. As I said, I think that authority was 9 generally--this wasn't novel to Environmental because 10 the company hired lots of consultants--was who had the 11 need and who had the, the budget to support that 12 additional assistance. 13 BY MS. BOWERS: 14 Q. At the plant level, would there have been 15 the budget to support that? 16 A. Well, if they were hired, the answer was 17 yes. If they weren't, the answer was no. 18 (Laughter.) 19 Q. Are you aware of the Anniston Plant ever 20 hiring outside consultants on environmental issues? 21 A. Yes. 22 Q. At what point in time? 23 A. Again, I'm not certain. I mean, I know they 24 were used in the Eighties and Nineties. I would guess 25 they were used before that. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053414 144 1 Q. Did Monsanto or does Solutia keep records of 2 the names of chemical suppliers? 3 A. I mean, I would have to deduce that in a 4 centralized standpoint, probably not, but certainly, 5 they, you know, back through purchasing orders, and 6 contracts, and things of that nature, I mean there are 7 a list of chemical suppliers. 8 Q. But there' s--other than that, there's no 9 list that's maintained? 10 A. Not that I'm aware of. Plants had to keep, 11 under OSHA requirements, lists of chemicals and hazard 12 sheets on chemicals, and as long as they met certain 13 criteria, so within plant books on OSHA hazardous 14 material safety data sheets, there's probably an 15 understanding of, you know, who suppliers were. 16 Q. The same question with respect to trucking 17 company records and railroad delivery records? 18 A. I think my answer would be generally the 19 same. I don't know of any centralized depository of 20 those, but certainly, they would have known who they 21 were dealing with and had records in shipping, 22 billing, invoicing, that would indicate who they dealt 23 with, consistent with records retention policies, I 24 would hope. 25 (Laughter.) Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053415 145 1 Q. Okay. With respect to the interface between 2 the plant-level organization and the corporate-level 3 organization, if there was an explosion, or a spill, 4 or some other catastrophe at a plant, was there any 5 official policy or procedure as to how corporate level 6 would be notified? 7 MR. GILHOUSEN: We're talking as to 8 Monsanto, itself? 9 MS. BOWERS: Starting with Monsanto and then 10 with Solutia. I want to know as to both. 11 A. You've asked several questions within there, 12 so I'm trying to figure out how to respond. We, we 13 did have, for a period of time, with respect to--there 14 was a time, and I forget under which statutes, that 15 you had to notify the government of spills, and we did 16 have a reporting and summarization procedure that did 17 periodically assemble that information for people in 18 the company to see, so there was a set of sort of 19 procedures on how to, how to do that. 20 BY MS. BOWERS: 21 Q. Did those procedures have a name? 22 A. Well, I think they were within these 23 worldwide environmental guidelines, and they may have 24 been something like, you know, hazardous spills 25 reporting procedures or something like that. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053416 146 1 Q. Who at the corporate level would the plant 2 contact? Who would be the first point of contact at 3 the corporate level on something like this? 4 A. Um, in general, these were, as I said, 5 periodically reported, so they just went into a--they 6 went into a system. I believe under --there were, 7 under certain prescribed conditions or statutory 8 requirements, where there may have been a more 9 specific and a more timely reporting requirement, and 10 under those, I think typically, the Law Department 11 would be the, the first point of contact to help them 12 decide is this or is it not, and what's your time, and 13 what do you have to do, and in conjunction with these 14 environmental managers we talked about were probably 15 aware of those conversations, so again, if there was a 16 specific requirement with a specific deadline for 17 reporting, that was probably between the location and 18 Law Department, the general collection of information 19 was done, as I recall, for awhile monthly, and then 20 monthly, reports were compiled and distributed. It 21 was more a post--it wasn't an actionable list, it was 22 just a summarization list. 23 Q. So the plant would compile a monthly report? 24 A. They would compile, yes, the basic data that 25 went into the plant report that would then go to--I Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053417 147 1 think at that time, we were collecting those at the 2 corporate staff, and at the operating unit or business 3 unit, they were getting their summaries, and then the 4 reports were prepared that included across the 5 company, across the businesses, and then specifically 6 at the individual plants. 7 Q. So it would go from the individual plant to 8 the operating company? 9 A. Yeah, it kind of went to the operating 10 company and to the corporate staff. 11 Q. And "corporate staff," you mean-- 12 A. And I think corporate staff was -- kind of had 13 the responsibility to aggregate the data and issue the 14 reports. 15 Q. Okay, when you say "corporate staff," who do 16 you mean in particular? 17 A. Well, at that time, it would have been 18 people within my organization working for me that 19 were --I think I actually, I probably did some of that 20 myself, too, for, for a period of time. 21 Q. Okay, so just to be clear for the record, it 22 would go from the plant to the business operating 23 unit, the operating company, to the Department of 24 Environmental--Environment, Safety and Health? 25 A. Well, what I'm saying is the plant would Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053418 148 1 issue a report and would probably simultaneously go to 2 the other two or three places, and then the corporate 3 people would summarize all of this and distribute a 4 compiled report. 5 MS. BOWERS: Okay. Can we take a quick 6 break before we go to documents? Just take about five 7 minutes? Thanks. 8 (Recess.) 9 BY MS. BOWERS: 10 Q. Mr. Pierle, I'd like you to take a look at 11 what we've marked as Solutia-Pierle Exhibit 15, and 12 I'll represent to you that these are various 13 organizational charts produced in this litigation by 14 your counsel, and I have attempted to put them in as 15 close to chronological order as I could get them. 16 With the agreement of your counsel, we have decided 17 that we're not going to go through each one of these 18 for each year, but I would ask that if there are any 19 of these that you believe are not accurate records of 20 Monsanto Corporation or of Solutia, Inc., that you 21 please let me know. 22 A. As we go through them? 23 Q. Well, we're not going to go through each 24 one. 25 A. Right. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053419 149 1 Q. So do you disagree that these are 2 organizational charts and records of Monsanto 3 Corporation or of Solutia? 4 A. I guess we agree to that. 5 MR. GILHOUSEN: Joe and I agree. 6 A. (Continuing) Yes. 7 BY MS. BOWERS: 8 Q. Okay. I just have a few specific questions 9 about some of the charts in here. If--because these 10 are in chronological order, rather than Bates stamp 11 order, it's going to be a little difficult, but maybe 12 this many (Indicating) pages into it, Bates stamp 876, 13 it's an organization chart dated January 1953. 14 Deborah brought us some magnifying glasses, but I 15 think she took them back. There they are. 16 A. 000876? 17 Q. Yes, 000876. 18 A. Okay. 19 (Witness peruses said 20 document.) 21 Q. To your knowledge -- 22 MR. GILHOUSEN: 53? 23 THE WITNESS: Mm-hmm. 24 BY MS. BOWERS: 25 Q. (Continuing) To your knowledge, is this an Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053420 150 1 accurate representation of the corporate structure of 2 Monsanto Corporation as of January 1953? 3 A. Yes. 4 Q. Looking at this chart, which of these staff 5 departments or operating divisions would the Anniston 6 Plant have been a part of? 7 A. I believe on this chart, it is probably part 8 of the Phosphate Operating Division. 9 Q. And what leads you to that conclusion? 10 A. In kind of perusing some of these in a 11 different order, that was my recollection of, of the 12 business, so I think, I think in '53--let me put it 13 this way; it would have been either part of the 14 Phosphate Division or Organic Chemicals Division, one 15 of those two. 16 Q. Okay. With respect to each of these staff 17 departments and operating divisions, would the top 18 person within each one of those have been a vice 19 president? 20 A. I'm not certain. 21 Q. Would the plants have fallen in a direct 22 report fashion under any of the staff departments? 23 A. No. 24 Q. Do you know who the head of the Phosphate 25 Department was at this time? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053421 151 1 A. I'd have to go back and find the specific 2 chart. 3 Q. At any point in time, are you familiar with 4 the name of anyone that was in charge of the Phosphate 5 Department? 6 A. No, because again, I have to refer to my 7 own--by the time I got there, I don't think that was 8 an op --an operating nomenclature. 9 Q. What was the Phosphate Division? 10 A. We had some businesses that were actually in 11 the process -- that made phosphorus and 12 phosphate-related products, so I believe it was just a 13 family of businesses associated with phosphate as part 14 of the product makeup. 15 Q. Were each of these operating divisions, were 16 they grouped by product that was made? 17 A. In looking at this, it was, it was, it was 18 different. For example, the Texas Division was more a 19 geographical. Meramec, I believe, it was more an 20 evolu--or a derivation of a business that had been 21 bought called, I think, Meramec Chemical, whereas 22 Organics was more homogenous of a variety of products 23 that had evolved over the, the, the start of the 24 company, so there's different--again, as I said, in 25 organizations, they were -- they fit some Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053422 152 1 business-related purpose, primarily. 2 Q. Was each, each staff department in a 3 separate physical location? 4 A. Probably at this company level, not a 5 hundred percent, but I suspect most of those were 6 probably here in the St. Louis area. 7 Q. Would, say, the Accounting Department be in 8 a separate building from the Advertising and Public 9 Relations Department, or -- 10 A. No, they may have all been in the same 11 building. 12 Q. Okay. 13 A. Or they may have been in, you know, more 14 than one. I don't, I don't recall at that time. 15 Q. Same question with respect to the operating 16 divisions. Would the merchandising division be in a 17 separate physical location from, say, the Meramec 18 Division? 19 A. I'm really not familiar with merchandising, 20 so that--I mean obviously, the Overseas Division was 21 probably in a different position than the Texas 22 Division. 23 Q. Right. 24 A. Yet at the same time, and I don't know this 25 for certain, but it's possible that, for example, Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053423 153 1 Organic Chemicals had some of their businesses were 2 overseas, so these were not intended to represent 3 physical divisions of businesses, or products, or 4 locations, they were intended to represent more 5 business and financial divisions within the company. 6 Q. So in 1953, would there have been people at 7 the Anniston Plant that may have directly reported to 8 another operating division other than the Phosphate or 9 Organic Chemical Operating Division? 10 A. Probably not, because typically, people at 11 the plant reported in through one, one business 12 reporting entity. 13 Q. On the next page, Bates stamp 875-14 A. Wow. 15 Q. The magnifying glass may come in handy on 16 this one. Actually, if you flip one, two pages to 17 Bates stamp 872, there's a little cleaner copy. 18 A. Okay. 19 Q. The difference is on Bates stamp 872, the 20 names are not filled in, so if it helps you to look at 21 both of them when we go through this, that's fine. On 22 Bates stamp page 872, it appears the Anniston Plant is 23 under the Inorganic Chemicals Division. At some 24 point, the Phosphate Division, it appears, had been 25 phased out between 1953 and 1954. Do you know why? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053424 154 1 A. Again, I think it's, it's just another way 2 of organizing, you know, the businesses. I don't 3 think there was any--I suspect somebody felt it was a 4 you--"Inorganic" was a broader and more accurate 5 definition of everything that was in there at the 6 time, not just "Phosphates." 7 Q. Was this Inorganic Chemicals Division the 8 only interface, if you will, between the Anniston 9 Plant and the corporate-level structure? 10 A. Let me put it this way. It would have been 11 the primary means of communication. We had--I mean 12 just--I won't give you an organizational history or 13 we'll be here all the time, but at some of the plants, 14 they only had one, like one thing, so it was clear 15 where they were, but at a plant like--at other plants 16 like Anniston's, where they, they may have been making 17 products in that plant that were basically financially 18 the responsibility from a profit-and-loss standpoint 19 in more than Inorganic Chemicals and therefore, that 20 unit, from a financial standpoint, certainly would 21 have had communications, contacts and that, with their 22 business units that may have been in another division, 23 but the management of the plant would have been 24 predominantly up and through the inorganic chemicals 25 unit. Anytime you want to cut me off on one of those Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053425 155 1 lessons, just let me know. 2 (Laughter.) 3 Q. Going back to page Bates stamp 875, I think 4 I need my magnifying glass to look at it. Under the 5 Inorganic Chemicals Division, do you recognize the 6 name of the person that's listed as the Vice President 7 and General Manager? It's all the way on the left. 8 A. Oh, I'm sorry, I'm with you now. Man, I 9 cannot really make that out. 10 Q. Okay. Okay, fair enough. 11 A. It looks like J. L. Christian. 12 Q. Do you know that Mr. Christian was at one 13 point the head of the Inorganic Division? 14 A. I believe he was, yes. 15 Q. Would an employee at the Anniston Plant 16 report to more than one division? 17 A. Not, not directly. As I indicated, if they 18 were running a unit at Anniston that was making a 19 product for the Organic Chemicals Division, then they 20 would have reported, communicated with somebody in 21 that division, but from a functional or from a, from a 22 functional reporting, and therefore, probably his 23 paycheck and, and that, it would have been through 24 the, the organization chart as shown here, in this 25 case, Inorganic. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053426 156 1 Q. If you flip over -- 2 A. They were called guest manufacturing 3 operations, so they weren't guests to Monsanto but 4 they were guests to the division that was running the 5 plant. 6 Q. Guests. Okay, who would determine that they 7 were guests? I mean-- 8 A. Well, they'd basically be a guest if they 9 were not--and this, again, I'm not trying to sound 10 crazy, here --if they weren't part of the host 11 organization, they were a guest, so I would say it was 12 just a loose, you know, "Are you part of this 13 division?" "No, I'm a guest," so you, you knew you 14 were a guest at that location. 15 Q. Okay, but they would still report up 16 through-- 17 A. Yes. 18 Q. --whoever their host was at that particular 19 point? 20 A. Yes. 21 Q. Okay. Then turning one, two pages to -- 22 A. I'll get these all out of order here. Oh, 23 they are out of order. 24 Q. Excuse me. Turning seven pages to Bates 25 stamp 866--it looks like this (Indicating), it's dated Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053427 157 1 at the bottom, very small, "September 1954." 2 A. Okay. 3 Q. And on this chart, it appears that Anniston 4 has been moved under the Organic Chemicals Operating 5 Division. 6 A. Yes. 7 Q. Do you know why Anniston was, was placed 8 under the Organic Chemicals Division? 9 A. I, I really don't. 10 Q. Would that have to do with the type of 11 products that Anniston was producing at that point in 12 time? 13 A. That would have had something to do with it, 14 and as I indicated, I think through this time period, 15 they were --that's why I was unsure which division they 16 were in, because they were making products for, for 17 both, and so at this point in time, they were, they 18 were just simply shifted. 19 Q. Was it unusual for a plant to be shifted 20 three or four times within a span of a year or two? 21 A. Well, I mean, I think the one, the one was 22 more a name change, so wasn't a shift, the Phosphates 23 to Inorganic, so I think this is the only shift I'm 24 seeing from division--or from operating division to 25 division. My recollection in my time period, it would Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053428 158 1 happen from time to time but, but not generally, and 2 being that it was a little bit smaller plant may have, 3 may have affected that a little bit, too. 4 Q. In terms of size, was it one of the smaller 5 plants, or one of--a medium-size plant? 6 A. Yeah, I would probably categorize from 7 large, medium, small, that it was mainly a small 8 plant. 9 Q. When you talk about the shift from Inorganic 10 to Organic, was that indicative of a shift in the 11 categorization of the products that Anniston was 12 producing, or was that a shift in the, the products, 13 themselves, that Anniston was producing? 14 A. I think at some point in time, here, 15 Anniston stopped making phosphate products, and it--I 16 don't know this for a fact, but it could have been 17 around that time that it had--because historically, it 18 had come out of its ownership from the Thirties sort 19 of in the phosphate sector, and that may have been a 20 factor that what they were making in phosphate or 21 inorganic they weren't making it anymore, so it was 22 better to put it in a, in a different place. 23 Q. Flipping two pages over to organizational 24 chart of the Medical Department -- 25 A. Whoops, forward were we going? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053429 159 1 Q. Forward, yes. I'm sorry, it's Bates stamp 2 864 . 3 A. Oh, I see. Okay, yeah. Mm-hmm. 4 Q. How did the Medical Department interface 5 with the Anniston Plant? 6 A. Urn-- 7 Q. If we need to go back to 866-- 8 A. No, I was looking for a, a date on this 9 which I don't, which I don't see. So your question 10 was how did this department interface with Anniston? 11 Q. Yes. Let's-- 12 A. Probably very, very little, I would suspect, 13 but the kinds of plant possible things that were done 14 here, you'll see this plant service through the 15 hygiene kind of component of this, and to the extent 16 that there was much interface there, it would probably 17 have been up through that area, and I think that's the 18 J. T. Garrett or the Jack Garrett that I had mentioned 19 in response to a prior question. 20 Q. With respect to these boxes that contained 21 stream pollution and atmospheric pollution, are these 22 the early precursors to the environmental department 23 that you referred to earlier? 24 A. I think the boxes in this case represent, 25 where there's a name, it actually represents a person, Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053430 160 1 and the things below it, I think those boxes generally 2 looked like they represent duties or subject matter 3 within these people, because the only people in this 4 department--and I'm, I'm presuming this is back in the 5 Fifties--were those four individuals. 6 Q. So Mr. Garrett would have been a person 7 early in the process, or excuse me, early in the chain 8 of having responsibilities for these type of 9 environmental issues that we discussed earlier? 10 A. In this case, for example, stream pollution, 11 this was about the time of the Federal Water Pollution 12 Act in the late Fifties, so I think Jack had some 13 subject assignments there, and atmospheric went to 14 Elmer Wheeler, so to the extent that somebody in the 15 company wanted to know something about that, these 16 would probably be the two resource people that they'd 17 go to at that time. 18 Q. So is it accurate to categorize this as kind 19 of the, the early beginnings of the environmental 20 department within Monsanto? 21 A. Well, it was to the extent that things were 22 handled at a corporate level at this time, that--these 23 were the only people there to deal with it. 24 Q. Would those people travel to the plants, to 25 the Anniston Plant in particular? Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053431 161 1 A. I, I don't know. 2 Q. Go in about fifteen pages to Bates stamp 3 848 . 4 A. I have it. 5 Q. Down at the bottom, there's a very small 6 date, looks like "4/69"? 7 A. Looks like it. It's an eye test. 8 MR. GILHOUSEN: I can't get my glasses up 9 far enough. 10 BY MS. BOWERS: 11 Q. What are the--I'm looking, starting with the 12 Monsanto Company Chairman, Board of Directors, then 13 going down to the President, CEO, and then coming down 14 to where there are three boxes that say "Group Vice 15 President," what does that refer to? 16 A. This, again, goes to this earlier discussion 17 where when they took more than one kind of individual 18 business group or business division and put it in a 19 group, then they had to have a group leader. 20 Q. So -- 21 A. So they became the group vice president 22 of--so they--and you'll see in that case, they had 23 different vice presidents or general managers running 24 the individual units below them. 25 Q. So a group would be a collection of a few Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053432 162 1 operating divisions? 2 A. That's pretty good. 3 Q. Okay. So the group vice president, the 4 group that would have contained the Anniston Plant 5 would be which group on this chart? 6 A. Um, well, I'd have to--without it being 7 specifically designated here, I'd have to look at some 8 more organizational charts to be sure of my answer on 9 that. 10 Q. Okay. Do you believe that Anniston was 11 still part of the Organic Chemicals Division in 1969? 12 A. It may have been, but I'm not certain. 13 Q. Do you recognize the name of the individual 14 on this chart that is the general manager of the 15 Organic Chemicals Division? 16 A. H. L.--I believe that's Howard Minckler, 17 which is probably M-i-n-c-k-l-e-r. "Howard" is not on 18 there, but "H" is. 19 Q. Did you know that Mr. Minckler was the 20 general manager of the Organic Chemicals Division? 21 A. Yes. 22 Q. Do you have believe that he would have been 23 the corporate-level person to whom the Anniston Plant 24 reported? 25 A. Well, it would have--it could have been, Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053433 163 1 again, I'm not certain, here, based on my last answer, 2 but it could have been within his organization; would 3 not have reported to him. I feel certain of that, but 4 someone in his organization. 5 Q. Going about 40 pages till we get to December 6 of 1963, it's Bates stamp 754 -- 7 A. It must be lying in there by itself 8 someplace. 9 Q. December '63. 10 A. Well, the reason I ask that, I got '52 -- 11 MR. GILHOUSEN: Go back this way. 12 THE WITNESS: It's not there. 13 A. I've got '52, '53--are your numbers on the 14 Bates numbers around 54 or what? 15 BY MS. BOWERS: 16 Q. Would go 760, then 754, 755, 56, 57 -- 17 A. I just happened to--754? 18 Q. 754. 19 A. Lucky day. 20 Q. What is the Chemstrand Committee? 21 A. This was--what's the time frame on this? 22 Q. December 1963. 23 A. Chemstrand was a, a set of businesses that 24 Monsanto had acquired, obviously, prior to this date, 25 and it was basically fiber businesses, and what this Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053434 164 1 looks like is it was being run by a, you know, a set 2 of senior Monsanto executive officers. I don't know 3 any more about that. 4 Q. Did they have any interface with the 5 Anniston department--Anniston Plant? 6 A. I wouldn't think so. 7 Q. Flipping to Bates stamp page 758, it's about 8 five pages-- 9 A. I have it. 10 Q. This is an organization chart, Monsanto 11 Chemical Company, Organic Chemicals Division, December 12 1963, and coming down from the Vice President and 13 General Manager to the Director of Manufacturing, did 14 the Anniston Plant report directly to the Director of 15 Manufacturing? 16 A. Yes. 17 Q. And the Director of Manufacturing reported 18 to Mr. Morris,-- 19 A. Yes. 20 Q. --who was the Vice President and General 21 Manager of the Organic Chemicals Division? 22 A. Yes. 23 Q. Was there anyone else on this organizational 24 chart or any other organizational chart that we've 25 looked at that the plant manager at Anniston would Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053435 165 1 have directly reported to on any issue? 2 A. No. I mean, we looked at charts other than 3 '63, okay? So I mean, I didn't--I just want to be 4 clear that I didn't see on any of the other charts we 5 looked at where it specifically noted the Anniston 6 plant manager and a direct reporting assignment. 7 Q. Was it your understanding that the Anniston 8 plant manager reported to the Director of 9 Manufacturing at this point in time? 10 A. In 1963? 11 Q. Yes. 12 A. Yes. 13 Q. Do you have any personal knowledge of the 14 Anniston plant manager ever reporting to anyone else 15 other than the Director of Manufacturing? 16 A. Of what? 17 Q. Within this particular business division. 18 A. Not that I'm aware of. 19 Q. Flipping a few pages, about ten pages, to 20 Bates stamp 747, it's an organizational chart of the 21 Monsanto Medical Department. 22 A. I have it. 23 Q. Looking at the box that says, "Manager, 24 Environmental Health, E. P. Wheeler, 25 A. Yes. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053436 166 1 Q. --and underneath, underneath that, are those 2 the job responsibilities of the Manager of 3 Environmental Health? 4 A. It appears that way, yes. 5 Q. Was Mr. Wheeler the first person that held 6 that position? 7 A. I believe so. 8 Q. Do you know who held that position 9 subsequent to Mr. Wheeler? 10 A. What, what concerns me on, on this is it 11 says it's February '66, and I think we had established 12 that Jack Garrett was in here someplace in-- 13 Q. If you turn to the next page, Bates stamp 14 748 -- 15 A. Mm-hmm. Okay, that helps, yes. 16 Q. So does that refresh your recollection as 17 to -- 18 A. Yeah, I think Elmer had general 19 responsibilities, and then he had people assisting him 20 on that, which is what comes under that, and I think 21 maybe a little more direct, again, we've already 22 discussed this department is what continued to evolve 23 over time into a larger department with additional 24 people that dealt with these subject matters. 25 Q. So to your knowledge, were Mr. Wheeler and Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053437 167 1 Mr. Garrett two, two individuals that had primary 2 responsibility for these issues in the early stages of 3 environmental regulation and compliance? 4 A. Um, again, they were the primarily--they 5 were primary on coordination but they would not have 6 been primary on compliance, so I'm just clarifying 7 again your--had a few more than one list, there, as to 8 what their responsibilities were. 9 Q. Okay. 10 A. So again, they were the knowledgeable 11 people, the people you could go to for some 12 consultation, but they were not involved in what I'd 13 call day-to-day operational compliance at the plant 14 level. 15 Q. If you'll flip about 25, 30 pages to Bates 16 stamp 688, it's an organizational chart, May of 1974, 17 looks like this. (Indicating). 18 A. I have it. 19 Q. What is the Industrial Chemicals Company? 20 A. I would say in the context of what we've 21 been discussing--and this would have been in '74--when 22 you see again he's a group vice president that headed 23 that up, it would have included what we've been 24 calling the Inorganic and Organic Divisions. 25 Q. So that group vice president would have Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053438 168 1 further divisions underneath him? 2 A. Um, yeah, business units if they were called 3 divisions, yes. 4 MS. BOWERS: That's all the questions I have 5 with this exhibit. 6 (Defendant's 7 Solutia-Pierle Exhibit 8 16 mark'd for 9 identification.) 10 BY MS. BOWERS: 11 Q. Mr. Pierle, I'd ask you to take a look at 12 what we've marked as Solutia-Pierle Exhibit 16 and ask 13 you just to look through these documents. 14 (Witness peruses said 15 exhibit.) 16 A. Okay. 17 Q. The first half of this stack are documents 18 that came out of folders marked "Phosphate Division," 19 and the second half are documents that came out of 20 folders marked "Organic." Do you believe that these 21 are, these records are organizational charts that 22 reflect the organization of the Phosphate Division and 23 then later the Organic Division? 24 A. Yes. Um, no, you said "and later, the 25 Organic Division"? I think they represent the Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053439 169 1 Phosphate Division and the Organic Division, which 2 were, at this time were probably separate divisions. 3 Q. Okay, so they were two separate divisions? 4 The Phosphate Division did not become the Organic 5 Division? 6 A. Well, again, you see the first set of 7 documents are from 1939, and the second set of 8 documents look like they're from 1971, so there was 9 considerable, you know, organization change, and I'd 10 have to really look at these a lot more closely to be 11 able, I guess, to specifically answer that question. 12 Q. Okay, fair enough, as long as we're in 13 agreement that these are records that accurately 14 depict the Phosphate Division for the years that are 15 marked on them. 16 A. That are marked, mm-hmm. 17 Q. In the second half, the organic half, it 18 starts with Bates stamp 1169, specifically I want to 19 direct your attention to Bates stamp page 1191, and 20 the page before it, as well, 1190, 1191. Page 1190 21 contained a rather blurry picture of Mr. Bilger? Are 22 you familiar with him? 23 A. Yeah, I believe he pronounced that BILL-gur. 24 Q. BILL-gur? 25 A. Yes. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053440 170 1 Q. Who is Mr. Bilger? 2 A. He was a director of, of what at this time 3 was the General Chemicals Unit, I guess, in the 4 Organic Chemicals Division. 5 Q. And on the next page, 1191, this list of 6 products, were those the list of products that 7 Mr. Bilger's division made? 8 A. Including the following page, as well, yes. 9 Q. So pages 1191, 1192, were the products that 10 Mr. Bilger's division made? 11 A. I believe so, yes. 12 Q. Page 1194,-- 13 A. Yes? 14 Q. --there is a reference to a Gene Jesse, who 15 was the plant manager at Anniston? 16 A. Yes. 17 Q. Do you know if Mr. Jesse still living? 18 A. I believe he is. 19 Q. Do you know where he lives? 20 A. I do not. 21 MS. BOWERS: That's all the questions I have 22 on this document. 23 (Defendant's 24 Solutia-Pierle Exhibit 25 17 mark'd for Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto WATER PCB-SD0000053441 171 1 identification.) 2 BY MS. BOWERS: 3 Q. Mr. Pierle, I'd like you to take a look at 4 what we've marked as Solutia-Pierle Exhibit 17 and ask 5 you to look at these documents. These are documents 6 that were produced to us in this litigation by your 7 counsel that appear to relate to the organization 8 within the Anniston Plant. Do you believe that that's 9 what these documents reflect? 10 A. I would say for the most part, yes. 11 Q. Which ones do you take issue with? 12 A. Well, your reference was to Anniston Plant, 13 and this indicates Anniston companies, and this 14 initial one I think is a Swan Chemical, so I'm not 15 sure everything that Swan operated was at Anniston. 16 That's my only point, and I don't know enough about 17 the specifics of this without looking at a lot more 18 charts over time to know if it, if it is purely only 19 the Anniston Plant or not or as they say, Anniston 20 companies. 21 Q. Okay. Are you prepared today to testify on 22 behalf of Solutia and Pharmacia about the organization 23 within the Anniston Plant? 24 A. I believe so. 25 Q. Okay. I call your attention to the second Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053442 172 1 page, document 171. 2 A. Yes? 3 Q. Which individual or job grouping on this 4 chart would have borne the responsibility for 5 environmental issues? 6 A. I guess I'm not, I am not certain as to 7 whether at this time it was a, you know, a distributed 8 responsibility or a very specific responsibility. 9 This is 1942, I guess, or 43. What this chart would 10 tell me is that there was not a full-time 11 environmental person working at the Anniston Plant 12 site. 13 Q. Okay, at the top of the document, there are 14 some lines that come off to the top, the Division 15 Engineer, Division Electrical Engineer, General 16 Medical Director, General Accounting. Are those 17 references to lines of communication to the corporate 18 structure? 19 A. Typically, you see there are dotted lines. 20 What that would typically mean in an organization 21 chart in these is that they also probably communicated 22 and reported to somebody within their function outside 23 of the plant, and it is not clear, and I'm, again, not 24 certain what that structure at that time, who else 25 those would have been to. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053443 173 1 Q. Do you know in what year someone at the 2 Anniston Plant--there was someone at the Anniston 3 Plant who had a full-time responsibility with regard 4 to environmental issues? 5 A. I know there was somebody there in the early 6 to mid Sixties, and I don't know--and thereafter, and 7 I don't, don't know whether there was someone there 8 sooner than that. 9 Q. Do you know who the first person to hold 10 this full-time role would have been? 11 A. I think you asked me that. I do not recall 12 his name. 13 Q. But this is the same job that you believe 14 Jerry Brown would have had at some point? 15 A. Sometime after that, yes. 16 MS. BOWERS: Okay. 17 (Defendant's 18 Solutia-Pierle Exhibit 19 18 mark'd for 20 identification.) 21 BY S. BOWERS: 22 Q. Mr. Pierle, I'd like you to take a look at 23 what we've marked as Solutia-Pierle Exhibit 18, and 24 I'll represent to you these were documents produced to 25 us by your counsel regarding the Monsanto Industrial Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053444 174 1 Chemical Company. Forgive me if I've asked this 2 before, but what was the Monsanto Industrial Chemical 3 Company? 4 A. At, at this time, it was basically, again, 5 kind of a group business organization that included, 6 again, predominantly the Inorganic and Organic 7 Chemical Business Units. 8 Q. So it wasn't, it wasn't a separate business 9 division in and of itself, it was more of a group that 10 contained business divisions? 11 A. Well, I think the answer is yes to both 12 those. It did contain that, but it was a separate 13 unit that contained all of those. Again, for 14 management and profit control, it was a, not a 15 separate legal unit but a separate internal unit for 16 purposes of managing these businesses. 17 Q. Would there be someone at the Monsanto 18 Industrial Chemical Company that would interface 19 directly with the plant? 20 A. At this time, I think there were, within one 21 of the business divisions--well, let me take that 22 back. This was in '75, and you are talking specific 23 with the Anniston Plant? 24 Q. Yes. 25 A. I'd have to look more fully and--as to Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053445 175 1 whether or not Anniston was in this group or not at 2 this time. I'd have to look, look more deeply at 3 these to understand that. 4 (Defendant's 5 Solutia-Pierle Exhibit 6 19 mark'd for 7 identification.) 8 Q. Mr. Pierle, I'd ask you to take a look at 9 the group of documents we've marked as Solutia-Pierle 10 19. 11 A. Yes. 12 Q. The third page, Bates stamped 17, was the 13 first time I found you on one of the charts. How long 14 were you the Environmental Manager? 15 A. I think I had that responsibility for 16 something less than two years. 17 Q. And while you were in this role, did you or 18 anyone who directly reported to you have any regular 19 contact with anyone at the Anniston Plant? 20 A. Um, no. 21 Q. Do you know if anyone in the Environmental 22 Policy Department would have had regular contact with 23 someone from the Anniston Plant? 24 A. I don't believe so, because our role was 25 predominantly federal regulations, legislation, Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053446 176 1 interface and interaction. We may have had, you know, 2 conversations, but there was no oversight or 3 management or direct, you know, work between, really, 4 this group and the people at the plant sites. 5 Q. Who is A. M. Ford? 6 A. I believe that's Alan Ford. 7 Q. Was he an attorney or is he an attorney? 8 A. No. 9 Q. What were the duties and responsibilities of 10 the Manager of Environmental Litigation? 11 A. That group that existed was providing what 12 I'd call technical assistance to the lawyers within 13 the company as they needed it with respect to 14 litigation matters that, that the lawyers were 15 handling. 16 Q. Do you know if the Manager of Environmental 17 Litigation maintained files or records? 18 A. I'm sure he had, you know, some personal 19 files, but I think most of the records that were 20 controlled or that he would have dealt with were 21 probably under the control of the Law Department. 22 Q. Flipping to the next page that's dated 23 5/13/81? 24 A. What's the Bates number on that? I'm sorry, 25 two pages over. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053447 177 1 Q. 18. 18? 2 A. Well, I went two in my group. 3 Q. Am I off one? 4 A. I'm with you onBates 18. 5 Q. Okay. I found you again. What title did 6 you hold at this time? 7 A. Well, this actually precedes the prior 8 document, and I was dealing with regulatory 9 management, water--specifically in the area of water, 10 water regulations. 11 Q. Did you have responsibility for water 12 regulations with respect to any of the activities at 13 the Anniston Plant? 14 A. No. 15 Q. Do you know if your colleagues, the 16 regulatory management with air, OSHA, TSCA or RCRA, 17 had any contact with the Anniston Plant? 18 A. Well, I'm not aware of it specifically. 19 Q. Are you aware of something called an Ad Hoc 20 Committee that was formed in the late 1960's, early 21 1970's at Monsanto regarding PCBs? 22 A. Yes. 23 Q. Who would that--who created that Ad Hoc 24 Committee? Do you know? 25 A. I believe it was a committee that was Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053448 178 1 sanctioned by the, one of the senior administrative 2 committees within the company. 3 Q. And organizationally, where would that 4 committee fall? Would it fall above the vice 5 presidents of the operating divisions? 6 A. No, I believe that committee was primarily 7 reporting into the business unit that was making PCBs. 8 Q. Do you know what business unit that was? 9 A. I'd have to go back through here and look at 10 those time charts and that. It was somewhere in the 11 Organic Chemicals Units. 12 (Defendant's 13 Solutia-Pierle Exhibit 14 20 mark'd for 15 identification.) 16 Q. Did you participate at all in that 17 committee? 18 A. In that committee? No. 19 Q. Did you participate in providing any 20 information to that committee? 21 A. Some of the work I was doing at a different 22 plant site I think was part of that committee's 23 activity. 24 Q. Okay, what type of work were you doing at 25 plant sites? I've understood you to say that in your, Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053449 179 1 in your job responsibilities, you didn't interface 2 with the plants. 3 A. I think there are two different time 4 periods. We're talking about--you asked about '70, 5 and in that time frame, then you asked about this 6 committee-- 7 Q. Okay. 8 A. --versus Eighties and beyond. In around the 9 late' 60-70, I was working in a separate plant, so I 10 was at the plant working with PCB matters as a part of 11 my job assignment. 12 Q. I ask you to take a look at what we've 13 marked as Solutia-Pierle Exhibit 20. 14 A. Okay. 15 Q. Do you know why organizational charts were 16 not issued by Monsanto in 1940 or '41? 17 A. I do not. 18 Q. Do you know who would know the answer to 19 that question? 20 A. No, I do not. 21 (Defendant's 22 Solutia-Pierle Exhibit 23 21 mark'd for 24 identification.) 25 BY MS. BOWERS: Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053450 180 1 Q. Mr. Pierle, I'd like you to take a look at 2 what we've marked as Solutia-Pierle Exhibit 21. 3 A. Yes. 4 Q. Are you familiar with an Environmental 5 Policy Committee within Monsanto? 6 A. Yes. 7 Q. What is the Environmental Policy Committee? 8 A. It was, again, a group of senior people in 9 Monsanto that were guiding the creation, the 10 enhancement, and implementation of environmental 11 policy matters for the company. 12 Q. Did you have any direct interaction with the 13 Environmental Policy Committee? 14 A. From time to time when I was on the 15 corporate staff. 16 Q. Did you participate in this time frame of 17 this particular document, February of 1980? 18 A. I didn't participate in this meeting. 19 Q. In paragraph 4, do you know what "this 20 emerging environmental problem" refers to? 21 A. My, my reading of that would be that it 22 basically is defined in the first sentence of that 23 paragraph, which is the increase in numbers of 24 environmental laws and regulations at the state level. 25 Q. Were the plants having trouble keeping up Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053451 181 1 with this, the number of regulations on their own? 2 MR. GILHOUSEN: Objection. We're getting 3 outside the idea of structure. 4 BY MS. BOWERS: 5 Q. (Continuing) I'm trying to get to--we've 6 talked about the burgeoning Environmental Affairs 7 Group on the corporate level. Just in terms of time 8 frame, is this the time frame when the corporate 9 environmental group started to grow both in size and 10 in stature? 11 A. The corporate group? 12 Q. Yes. 13 A. That's correct. 14 Q. Okay. 15 A. Prior to this and through this time period. 16 MS. BOWERS: Okay, that's all the questions 17 I have about that document. 18 MR. TURNER: I don't have any other 19 questions. Let's see if we have anybody on line, if 20 anybody is still alive. 21 MS. BOWERS: Anybody awake on the phone? 22 MS. O'NEAL: I don't have anything. 23 MS. RUTLEDGE: I don't have anything. 24 MR. TURNER: Who was the second? 25 MS. RUTLEDGE: Stephanie. Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053452 182 1 MS. ELLERHORST: This is Shelly Ellerhorst. 2 I don't have any questions. 3 MR. McMAHON: I don't have any questions. 4 STEPHANIE RUTLEDGE: I don't have any 5 questions. 6 MR. PARKER: This is Elton Parker. I 7 stepped in for Lianne Mantione, who was here at the 8 beginning of the day, and I don't have any questions. 9 MR. TURNER: I think that's it. 10 (Whereupon, at 3:04 P.M., the 11 deposition was concluded.) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053453 183 1 State of Missouri. ) 2 ) SS. 3 City of St. Louis ) 4 I, J. Bryan Jordan, a Notary Public in 5 and for the State of Missouri, duly commissioned, 6 qualified and authorized to administer oaths and to 7 certify to depositions, do hereby certify that 8 pursuant to Notice in the civil cause now pending and 9 undetermined in the United States District Court for 10 the Northern District of Alabama 11 ,Magistrate Judge Green, to be used in the trial of 12 said cause in said court, I was attended at the 13 offices of Husch & Eppenberger, LLC, in the County of 14 St. Louis, State of Missouri, by the aforesaid witness 15 and by the aforesaid attorneys, on the 29th day of 16 April, 2005. 17 The said witness, being of sound mind 18 and being by me first carefully examined and duly 19 cautioned and sworn to testify the truth, the whole 20 truth, and nothing but the truth in the case 21 aforesaid, thereupon testified as is shown in the 22 foregoing transcript, said testimony being by me 23 reported in shorthand and caused to be transcribed 24 into typewriting, and that the foregoing pages 25 correctly set forth the testimony of the Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053454 184 1 aforementioned witness, together with the questions 2 propounded by counsel and remarks and objections of 3 counsel thereto, and is in all respects a full, true, 4 correct and complete transcript of the questions 5 propounded to and the answers given by said witness; 6 that signature of the deponent was not waived by 7 agreement of counsel. 8 I further certify that I am not of 9 counsel or attorney for either of the parties to said 10 suit, not related to nor interested in any of the 11 parties or their attorneys. 12 Witness my hand and notarial seal at 13 St. Louis, Missouri, this 10th day of May, 2005. 14 15 16 J. Bryan Jordan 17 Certified Court Reporter 18 State of Missouri 19 My License expires: January 1, 2006 20 21 22 23 24 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053455 1 Gore Perry Gateway & Lipa Reporting 2 3 4 Joseph G. Nassif, Esq. 5 Husch & Eppenberger, L.L.C. 6 190 Carondelet Plaza, Suite 600 7 St. Louis, MO 63105-3441 8 9 Enclosed please find the Original Signature pages 10 and errata sheets for the deposition of: 11 MICHAEL A. PIERLE taken 4/29/2005 in the case of: 12 Solutia, et al., vs. McWane, et al. 13 Please read your copy of the transcript, noting 14 any corrections on the enclosed erratta sheets, 15 and return all pages for filing in court to: 16 Bryony Helen Bowers, Esq. 17 Troutman Sanders, L.L.P. 18 600 Peachtree Street, N.E., Suite 5200 19 Atlanta, GA 30308-2216 20 21 Your prompt cooperation will be appreciated. 22 Sincerely, 23 24 Gore Perry Gateway & Lipa Reporting 25 185 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053456 1 Page Line Should Read: 2 Reason for change: 3 4 Page Line Should Read: 5 Reason for change: 6 7 Page Line Should :Read: 8 Reason for change: QJ 10 Page Line Should Read 11 Reason for change: 12 13 Page Line Should Read 14 Reason for change: 15 16 Page Line Should Read 17 Reason for change: 18 19 Page Line Should Read 20 Reason for change: 21 22 Page Line Should Read 23 Reason for change: 186 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053457 1 Page Line Should Read: 2 Reason for change: 3 4 Page Line Should Read: 5 Reason for change: 6 7 Page Line Should :Read: 8 Reason for change: QJ 10 Page Line Should Read 11 Reason for change: 12 13 Page Line Should Read 14 Reason for change: 15 16 Page Line Should Read 17 Reason for change: 18 19 Page Line Should Read 20 Reason for change: 21 22 Page Line Should Read 23 Reason for change: 187 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053458 1 Comes now the witness, MICHAEL A. PIERLE, 2 and having read the the foregoing transcript 3 of the deposition taken on the 4/29/2005, 4 acknowledges by signature hereto that it is a 5 true and accurate transcript of the testimony given 6 on the date hereinabove mentioned. 7 8 9 10 MICHAEL A. PIERLE 11 12 Subscribed and sworn to me before this 13 day of ,2005. 14 My Commission expires 15 16 17 18 Notary Public 19 20 21 22 23 188 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053459 I COURT MEMO 2. 34 5 Solutia, et al., vs. McWane, et al. 6 CV-03-PWG-134-E 7 8 CERTIFICATE OF OFFICER AND 9 STATEMENT OF DEPOSITION CHARGES 10 II DEPOSITION OF MICHAEL A. PIERLE 12 TAKEN ON BEHALF OF THE DEFENDANT 13 4/29/2005 14 Name and address of person or firm having custody of 15 the original transcript: 16 Bryony Helen Bowers 17 Troutman Sanders LLP 18 600 Peachtree St, NE, Nations Bank Plaza, 19 Atlanta, 20 21 22 GA 30308 23 24 189 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053460 1 ORIGINAL TRANSCRIPT TAXED IN FAVOR OF: 2 Wendlene M. Lavey 3 Squire, Sanders & Dempsey 4 4900 Society Center, 127 Public Square 5 Cleveland, OH 44114 6 Total: 7 1 ONE COPY - TAXED IN FAVOR OF: 8 Joseph G. Nassif 9 Husch & Eppenberger 10 190 Carondelet Plaza, Suite 600 11 St. Louis, MO 63105 12 Total: 13 1 ONE COPY - TAXED IN FAVOR OF: 14 Bryony Helen Bowers 15 Troutman Sanders LLP 16 600 Peachtree St, NE, Nations Bank Plaza, 17 Atlanta, GA 30308 18 Total: 19 1 ONE COPY - TAXED IN FAVOR OF: 20 Shelly Ellerhorst 21 Alston & Bird, LLP 22 One Atlantic Center, 1201 West Peachtree 23 Atlanta, GA 30309 24 Total: 25 1 ONE COPY - TAXED IN FAVOR OF: 190 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053461 1 D. Bart Turner 2 Maynard, Cooper & Gale 3, 4 Birmingham, AL 5 Total: 6 1 ONE COPY - TAXED IN FAVOR OF: 7 Lynne Stephens O'Neal (Leitman 8 Leitman, Siegal, & Payne P.C. 9 600 North 20th Stree, Suite 400 10 Birmingham, AL 85203 11 Total: 12 1 ONE COPY - TAXED IN FAVOR OF: 13 Allison E. McAdam (Resolution 14 Resolution Law Group 15 3717 Mount Diablo Rd, Suite 200 16 Lafayette, CA 17 Total: 18 19 Upon delivery of transcripts, the above 20 charges had not been paid. It is anticipated 21 that all charges will be paid in the normal course 22 of business. 23 GORE PERRY GATEWAY & LIPA REPORTING COMPANY 24 515 Olive Street, Suite 700 25 St. Louis, Missouri 63101 191 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053462 1 IN WITNESS WHEREOF, I have hereunto set 2 my hand and seal on this day of 3 Commission expires 4 5 Notary Public 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 192 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto .. WATER PCB-SD0000053463 [& - 24] Transcript Word Index & 12 (cont.) 1939 1999 & 190:1 191:1 192:1 169:7 18:4,8 112:12 124:25 2:18 3:4 4:4,14 5:3,13 1201 1940 2 25:17 119:9 183:13 185:1,1 4:6 190:1 179:16 2 185:1 190:1,1,1 191:1,1,1 127 1942 7:5 13:4,6,11,18 14:13,17 0 000876 149:16,17 5:5 190:1 13 7:5,16 115:2,6 185:1 186:1 187:1 188:1 189:1 190:1 172:9 1943 17:23 1953 00532 191:1 192:1 149:13 150:2 153:6,25 2:23 134 03 1:4 2:8 189:1 1:4 2:8 189:1_____________ 14 1954 153:25 157:1 1955 1 7:17 117:13,17 185:1 186:1 118:17 1 7:4 11:17 12:3,5,10,24 187:1 188:1 189:1 190:1 191:1 192:1 1960 100:5 101:25 27:21 48:24 87:9 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 20 7:23 178:14 179:13 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 200 6:4 191:1 2000 124:25 13:10 14:4,13,17 27:22 47:21 56:23 83:12 84:1 91:7,11,16 103:17 110:16 110:18 184:19 185:1 186:1 15 7:18 14:3 118:10 121:24 124:9 148:11 185:1 186:1 187:1 188:1 189:1 190:1 1960's 9:1732:1333:11,11 95:12 177:20 1963 2000-2001 25:2 2001 111:21 187:1 188:1 189:1 190:1,1 191:1 192:1 163:6,22 164:12 165:10 2002 190:1,1,1 191:1,1,1 192:1 10 7:13 78:18 91:19 98:2,6 121:24 185:1 186:1 187:1 16 7:19 124:9 168:8,12 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 1966 20:1,23 26:8 30:22 31:1 1967 74:4,7,13 76:15,21,23 25:3 115:8,16,17 2003 9:14 30:17 2004 188:1 189:1 190:1 191:1 168 81:22 118:18 2:22 192:1 103 7:14 10th 7:19 17 7:20 170:25 171:4 175:12 185:1 186:1 187:1 188:1 1969 162:11 1970 21:11 83:13,23 85:15 92:19 2005 1:12 183:16 2006 184:19 184:13 188:1 184:13 11 7:14 103:7,11 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 189:1 190:1 191:1 192:1 170 7:20 171 172:1 92:23 118:18 1970's 63:23 86:6 90:1,13 142:5 177:21 1971 202 5:18 205 4:185:19 205-251-5900 111 7:15 115 7:16 173 7:21 175 7:22 26:6 169:8 1972 92:17,23 94:8 118:19 1974 5:17 20th 5:14 191:1 21 1169 169:18 178 7:23 26:11 97:7 118:19 167:16 1975 7:24 179:23 180:2 185:1 186:1 187:1 188:1 189:1 117 7:17 118 7:18 1190 179 7:24 18 7:21 173:19,23 177:1,1,4 185:1 186:1 187:1 188:1 22:5 26:12 1976 97:20 118:19 1977 140:4 190:1 191:1 192:1 216 5:7,8 22 185:1 186:1 187:1 188:1 169:20,20 1191 169:19,20 170:5,9 1192 170:9 189:1 190:1 191:1 192:1 19 7:22 25:2 175:6,10 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 1978 98:8 99:16 118:19 1980 23:12 100:6 128:14 180:17 1980's 189:1 190:1 191:1 23 185:1 186:1 187:1 189:1 190:1 191:1 23 rd 192:1 188:1 192:1 1194 170:12 12 7:4,15 111:14,18 185:1 190 2:18 3:5 185:1 190:1 1901 4:15 90:13 1994 103:13 1997 111:20 24 185:1 189:1 190:1 191:1 192:1 186:1 187:1 188:1 189:1 45:23 119:16,24 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053464 [2400 - 77] 2400 4:16 24th 17:23 25 167:15 185:1 190:1 191:1 192:1 253-8695 4:9 254-1238 4:18 254-1999 4:19 284-0840 6:6 284-0870 6:7 29 1:12 29th 2:21 183:15 3 3 7:6 13:20,22 14:1,13 27:21 47:7,9 49:10 50:7 52:22 53:5 54:19 59:17 77:16,20 81:19 87:9 105:22 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 3:04 2:21 182:10 30 1:142:168:2 11:25 27:17 57:2 167:15 3-000304 70:19 30308 189:1 190:1 30308-2216 3:18 185:1 30309 190:1 30309-3424 4:7 305 72:11 306 73:16 314 3:8 314-480-1500 3:7 314-480-1505 3:9 323-2197 5:19 338 77:18 340 79:3 347 80:25 35203-2618 4:17 36 14:5,6,10,13 27:21 56:9,10 57:2 87:9 3717 6:4 191:1 372 81:12 382 81:18 4 4 7:7 50:2 54:20 64:7,9 67:2 77:22 79:3 80:22 81:2,13 81:14 107:6,7 116:22 180:19 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 4/29/2005 185:1 188:1 189:1 4/69 161:6 40 163:5 400 5:15 191:1 404 3:19,20 4:8,9 41 179:16 417 83:17 43 172:9 439 84:1 44114 190:1 44114-1304 5:6 446 85:13 47 7:6 479-8471 5:7 479-8780 5:8 480-1818 3:8 4900 5:4 190:1 499 91:19___________________ 5 5 7:8 69:24 70:4 72:11 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 5.000 25:24 5/13/81 176:23 50.000 25:15 507 92:10 515 191:1 52 163:10,13 5200 3:16 185:1 53 149:22 150:12 163:13 54 163:14 56 163:16 57 163:16__________________ 6 6 1:142:167:9 8:2 12:1,23 13:11 27:17 51:6 68:20,21 68:22 80:25 83:5,10 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 600 2:19 3:5,17 5:14 185:1,1 189:1 190:1,1 191:1 60-70 179:9 63 163:9 165:3 63101 191:1 63105 190:1 63105-3441 3:6 185:1 64 7:7 66 166:11 666 98:12 67 71:17 688 167:16 69 7:8 692 102:14__________________ 7 7 7:10 52:6 56:23 78:15 85:13,14 90:25 91:5 92:11 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 70 92:21 93:6 179:4 700 191:1 701 18:1 70's 9:17 72 93:6 726 103:17 727 107:5 74 167:21 747 165:20 748 166:14 749 109:15 75 174:22 754 163:6,16,17,18 755 163:16 758 164:7 76 93:24 94:3 98:15 140:4 141:14 760 163:16 77 93:24 94:3 98:15 141:14 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053465 [770 - anniston's] 770 962-6686 additional 17:25 3:20 68:2 94:8 143:12 166:23 8 97 address 8 7:12 19:19,21 119:17 121:3 17:24 92:25 189:1 6:13 7:11 73:17 96:24 97:5 185:1 186:1 187:1 188:1 123:15,19 124:19 125:3 98 addressed 109:21 189:1 190:1 191:1 192:1 7:13 addresses 8/22/02 117:19 80 986-5023 5:18 99 116:22 adhered 113:6 81:24 83 7:9 848 19:21 a.m. 2:21 a adherence 32:3 administer 31:25 183:6 161:3 able administration 85 23:8,13 142:17 169:11 absence 32:22 35:9 administrative 85203 5:16 191:1 27:2 access 178:1 adopted 86 23:8,13 864 48:9 accounting 152:7 172:16 140:4 adverse 8:4 159:2 866 accurate 148:19 150:1 154:4 160:18 advertising 152:8 156:25 159:7 872 153:17,19,22 188:1 accurately 169:13 affairs 22:18,20 23:2,11 26:16 181:6 874 115:24 acknowledges 188:1 affirmative 43:19 875 116:21 153:13 155:3 876 acquainted 34:13 acquired aforementioned 184:1 aforesaid 149:12 163:24 8:19 183:14,15,21 881-7000 act ag 4:8 885-3063 160:12 action 109:2 129:13 age 3:19 137:7 8:17 9 Q 7:12 75:25 97:13,19 185:1 186:1 187:1 188:1 189:1 190:1 191:1 192:1 9:06 2:21 90 7:10 9205 4:19 925 6:6,7 94549 6:5 96 7:11 119:17 actionable 146:21 activities 19:15 133:6 177:12 activity 106:19 178:23 actual 45:13 ad 177:19,23 adad 70:19 adad3-000003 65:13 added 93:2 addition 94:8 agencies 105:23 agency 16:7 agency's 27:1 aggregate 147:13 aggregation 129:2 agree 8:6 149:4,5 agreement 17:10,13 50:24 148:16 169:13 184:7 agricultural 109:3,3 120:22 ahead 57:21 90:8 air 93:17 136:7 177:16 al 1:2,6 2:5,104:175:16 185:1,1 189:1,1 191:1,1 alabama 2:2 18:10 183:10 alan 176:6 alive 90:22 181:20 alleged 137:3 allison 6:2 191:1 allison.mcadam 6:8 allowed 8:5 104:3 alluded 45:17 alston 4:4 190:1 alston.com 4:10 ambitions 61:24 america 3:16 amount 34:11 amsouth 4:16 amused 61:16 anniston 21:21 30:12,13 47:21,24 48:13,19,24 52:14 63:22 87:13,17 88:1,6,18,18,21 89:6,8,13 90:3,15 95:1,5,12 96:2,7,9 100:4,11 102:6,9 107:12 108:21 111:8 122:5 122:7,12,16 134:21 135:2,8 138:14,25 139:5 143:19 150:5 153:7,22 154:8 155:15,18 157:3,7,11 158:11,13,15 159:5,10 160:25 162:4,10,23 164:5,5 164:14,25 165:5,7,14 170:15 171:8,12,13,15,19 171:19,23 172:11 173:2,2 174:23 175:1,19,23 177:13 177:17 anniston's 154:16 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053466 [annual - basis] annual approval assume avenue 25:11,19 35:2 113:7 137:9 142:24 36:2 43:13 49:6 78:21 4:15 140:18 approximate assuring awake annually 110:14 128:12 42:7 181:21 25:12 27:10 34:24 113:9 approximately atlanta aware 118:25 30:15 59:3 90:19 95:21 3:13,18 4:7 9:1,2 185:1 14:15 18:11 37:17,23 43:1 answer 132:12 189:1 190:1,1 44:16 52:18 53:3,14 55:15 8:8 17:17 28:5,21 29:2,4,19 april atlantic 60:20 74:23 83:21 86:12 39:24 43:9 44:20 46:2 48:3 1:12 2:21 97:7,20 103:13 4:5 190:1 89:1 92:14 104:13 107:2 50:25 53:9 58:16 60:18 118:19,19 183:16 atmospheric 143:19 144:10 146:15 62:3,4,20 63:14,15,17,19 archives 159:21 160:13 165:18 177:18,19 71:2 74:19 78:11 79:11 76:1,2,7,13,17 77:10 attached awhile 81:9 82:16 86:14,15 87:25 archivist 44:17 139:7 146:19 110:12 118:23 122:21,25 69:19 77:7 138:11 143:16,17 144:18 area attempt 85:6 87:18 b 162:8 163:1 169:11 174:11 179:18 answers 10:21 87:24 184:5 anthony 9:5 anticipated 191:1 anybody 57:14 92:20,22 101:2 122:2 attempted 152:6 159:17 177:9 148:14 areas attended 12:17 13:2,12 14:25 19:11 18:23 183:12 36:21 52:16 56:8 57:4,17 attention 57:22 77:12 96:17 102:2 13:11 14:4 33:13 75:25 125:25 126:2 141:5 95:8 101:11 169:19 171:25 asked attorney 30:4 37:19 38:19 43:13 16:13,1929:8 30:1963:19 18 15 18 26 7 back 1416 29 14 15 40 7 4T7 58:11,23 71:8,17 73:21 81:1 88:8,17 95:9 99:24 101:24 110:11 144:5 149:15 151:1 155:3 159:7 1604 16311 17422 1789 42:19 136:14 142:14 181:19,20,21 anymore 84:21 158:21 82:13 91:22 115:5 145:11 82:18,22 104:22 105:13 173:11 174:1 179:4,5 136:13 176:7,7 184:9 asking attorneys 28:1,18,19 29:7,8,21 39:20 30:1 57:20 136:9,15,17,20 21:23 28:7 backtrack 23'9 anytime 93:7 154:25 56:1862:1580:12,15,17 183:15 184:11 87:7,20,21 99:20 108:23 audible 113:10 114:5,6 apologize aspect 46:6 115:14 139:6 141:19 53:19 10:21 audit 3 16 189 1 190 1 apparent 84:24 aspects 66:22 138:9 140:2 107:22 108:22 109:12 128:12,17,23 130:4,12 12224 1231 appear 84:9 89:19 171:7 assemble 145:17 131:21,23 132:9,14 audited 4911 appearances 3:1 appearing 5:2,12 6:2 appears 68:10 81:24 82:24 83:18 assets 122:5,9,10 assigned 126:2 assignment 165:6 179:11 108:21 auditing 108:25 auditors 78:16 audits 1175 12511 bart 413 1911 Uadcu 10113 1631 84:6 153:22,24 157:3 166:4 assignments 107:7,8,10,21 108:2,13,14 application 160:13 108:24 130:24 131:4,6,12 104:8 assistance 131:14 applications 89:16 130:7 142:11 143:12 authority 112 20 23 113 12 basic 88:23 146:24 104:1 applied 36:13,20 63:3,6 112:14,16 apply 81:9 112:6 115:11 116:23 117:24 118:1 appreciated 185:1 176:12 assistant 104:21 assisting 166:19 associate 132:22 134:9,15 associated 13:16,25 14:8 142:12 143:6 143:8 authorizations 103:17 authorized 11:1063:8 183:6 available 14:24 50:22 137:4 138:3 19:11 24:4 25:3 26:17 4016 5T16 54 10 6T11 67:13 109:10 116:10,11 12012 12T12 12819 129:15 130:20 141:2 154:17 156:8 163:25 174:4 18022 appropriate 40:21 131:20 151:13 142:15 25:6 39:23 86:1 108:2 130:14 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053467 [batch - calls] batch ben 79:13,14,15 20:24,25 bates best 65:10 70:18 77:17 79:2 52:16 80:24 81:12,18 83:16,25 better 85:12 91:18 92:10 98:11 43:11 158:22 102:13 103:16 107:5 beyond 109:14 115:24 116:21 94:6,10 111:9 179:8 149:10,12 153:13,17,19,22 bilger 155:3 156:24 159:1 161:2 169:21 170:1 163:6,14 164:7 165:20 bilger's 166:13 167:15 169:18,19 170:7,10 175:12 176:24 177:4 bill began 169:23,24 94:1 95:24 104:1 108:25 billing beginning 144:22 72:15 109:22 110:2 137:11 binder 182:8 67:10 beginnings bird 160:19 4:4 190:1 begun birmingham 78:6 4:175:16 191:1,1 behalf birth 2:17 11:5,8,11 13:16,25 17:22 14:9 16:9,22 30:5 48:1 bishop 171:22 189:1 76:25 belief bit 28:18 29:9 136:25 158:2,3 believe blank 11:10 13:24 14:8 15:9,11 65:19 20:24 21:5,11 22:17,23 blurry 23:12,21 24:11,16,1825:14 169:21 26:6 27:20 28:10,14 29:17 blush 30:22 31:9 33:6,18 34:3 57:23 35:17 36:20 41:21 43:11,20 board 44:12 45:1,18 47:6 48:17 123:19,21,23,24 161:12 51:16 55:3 63:21,23 65:25 bob 67:1,4 70:10,16 78:3 81:5 124:25 81:23 82:19,22 83:13 85:15 bold 90:10,23 91:8,17 93:24 68:22 97:8,20 98:8,25 103:13,21 books 107:9 111:21 112:8 113:8 75:18 144:13 115:8 117:20 119:1,6,8,13 borne 121:2 123:12,25 124:25 172:4 125:9 131:25 132:11,15 boss 134:7 137:11,13 138:21 20:24,25 42:9 139:1,13,18 146:6 148:19 bottom 150:7 151:12,19 155:14 65:11 70:19 157:1 161:5 162:10,16,22 166:7 168:20 bottoms 169:23 170:11,18 171:8,24 32:1 173:13 175:24 176:6 bought 177:25 178:6 151:21 belleau boundaries 15:6,10,20 16:19 59:8,10 94:12 63:19 bowers 3:14 6:13 8:1,12,14,22,25 bowers (cont.) budgeted 11:13,20 12:2,8,25 13:4,9 135:1,5 136:6 17:16 21:22,25 28:1,9,18 budgeting 28:23 29:3,7,13,20 33:20 135:15,17,24 136:2 39:22,25 47:5,14,17 53:1 budgets 56:9,22 58:18,23,24 64:12 75:8 135:14 142:19 143:2 64:18 69:21 70:2 80:12,23 building 83:3,8 88:5,15 91:3 97:2,16 88:16 152:8,11 98:4 103:9 107:14 111:10 buildings 111:16 115:4 117:15 118:3 121:13 118:12 120:5,8,9 122:22 bullet 123:4,8,10 133:1,4 135:6,7 110:17,17 143:5,13 145:9,20 148:5,9 burgeoning 149:7,24 161:10 163:15 181:6 168:4,10 170:21 171:2 burn 173:16,21 179:25 181:4,16 114:6 181:21 185:1 189:1 190:1 burned box 114:12 96:19 165:23 burning boxes 114:5,8 61:18 100:15 159:20,24 business 160:1 161:14 19:12 24:23 27:11 32:24 branchfield 37:1,1 71:6 73:23 74:21 49:7 52:8 102:20 107:18,22,24 109:3 break 109:4 116:1,6,9,12,17 58:19 111:10 118:4 148:6 121:16 124:3,8 125:2,4,16 brent 125:20,23,24 126:2,6 127:2 3:3 127:4,18,20,21 128:4 129:2 brent.gilhousen 130:9 147:2,22 150:12 3:11 151:20 152:1 153:5,11 briefly 154:22 161:18,18 165:17 14:21,22 168:2 174:5,7,8,10,21 broad 178:7,8 191:1 49:17 53:8 60:17 businesses broader 50:9 74:1 112:4 120:13,15 154:4 120:17,19,21,25 121:12 broadly 126:4 129:10 147:5 151:10 54:2 151:13 153:1,3 154:2 broke 163:23,25 174:16 118:13 c brought 149:14 brown 95:19 96:1 139:7 173:14 ca 6:5 191:1 call 11:17 12:2 102:18 124:10 bryan 139:18 141:5 167:13 2:22 183:4 184:16 bryony 3:14 8:25 185:1 189:1 190:1 171:25 176:12 called 20:6,15 21:15 35:24 43:25 72:25 76:25 114:2 116:20 bryony.bowers 119:8,21 128:20 151:21 3:21 budget 156:2 168:2 177:19 calling 75:10 130:15,20,22,24 131:2 133:22 134:21 167:24 calls 135:22,22 136:3 142:15,16 143:11,15 27:24 28:16 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053468 [campus - committee] campus centralize characterization clarifying 69:10 89:2 127:8 29:2 167:6 capacity centralized charge classifications 20:22 54:14 55:6,6 95:9 144:4,19 32:19 40:13 69:19 76:20 61:12 96:6 112:13 centrally 116:1 151:4 cleaner capture 73:22 charged 153:17 44:5 ceo 77:8 cleaning career 123:22,25 124:1,5,11,19,24 charges 113:2 26:10 127:6 129:21,22,24 161:13 189:1 191:1,1 cleanup carefully certain chart 19:15 183:18 10:2 30:18 33:18 34:8,11 71:18 128:16 132:10 clear carl 34:20 35:23 38:14,22 40:12 138:23 149:13 150:4,7 10:24 17:19,20 42:24 117:5 125:11 48:23 49:5 50:24,25 52:7 151:2 155:24 157:3 158:24 114:17 147:21 154:14 carondelet 54:20 55:1,21 65:16 75:6 162:5,14 164:10,24,24 165:4 172:23 2:19 3:5 185:1 190:1 76:18 77:11 80:19 82:21 165:20 167:16 172:4,9,21 clearly carried 84:8 90:10,11 91:23 99:5 charts 46:12,13 69:5 32:14 33:5 100:23 103:20 104:1,2 71:16,25 96:9,12 100:15 Cleveland case 107:19 108:5,11 114:4 148:13 149:2,9 162:8 165:2 5:6 190:1 1:4 2:8 8:19 30:14 42:14 119:11 122:15,19 125:12 165:4 168:21 171:18 client 72:6 92:3 108:9 155:25 131:5,15 132:3 134:10 175:13 178:10 179:15 29:8 159:24 160:10 161:22 140:10 141:4,23 143:23 chemical close 183:20 185:1 144:12 146:7 150:20 65:8 109:5 120:15,16,25 113:23 132:19 148:15 cases 152:25 162:12 163:1,3 129:13,13,16 144:2,7 closely 38:18 49:20 71:21 76:13 172:6,24 151:21 153:9 164:11 169:10 catastrophe certainly 171:14 174:1,2,7,18 coaching 145:4 37:17 51:20 144:4,20 chemicals 28:24 29:1 categorical 154:20 109:3 144:11,12 150:14 coeur 141:5 certificate 153:1,23 154:7,19,24 155:5 69:10 categorization 189:1 155:19 157:4,8 162:11,15 colleagues 45:16 158:11 certification 162:20 164:11,21 167:19 177:15 categorize 32:2 33:1 37:16 40:19,20 170:3,4 178:11 collected 158:6 160:18 41:3,22 43:5 80:3 102:14 chemstrand 38:19 category 102:17 113:20 163:20,23 collecting 45:6,12 110:9 certifications chief 147:1 cause 41:7,9 42:1,6 112:24 113:8 71:5 collection 183:8,12 113:16 Christian 107:18 114:1 146:18 caused certified 155:11,12 161:25 183:23 2:22 184:17 chronological collectors cautioned certify 148:15 149:10 113:24 183:19 116:2 183:7,7 184:8 circulated college ceased cessation 137:6 18:12 61:25 63:22 62:2 64:1 citation coming center chain 30:14 113:14,19 161:13 164:12 4:5 48:21,25 51:14 55:20 53:25 160:7 city comment 60:3 61:14 68:23 69:2,3,12 chairman 51:13 183:3 71:9 69:16 72:12,12,17,23,24 24:9 161:12 civil commerce 73:1,3,5,7,8,13 119:9 chance 8:6 18:19 183:8 26:15 130:22 131:2 190:1,1 64:22 claim commission centers change 77:24 188:1 192:1 46:22 72:20 73:6 75:8 124:12 128:7 157:22 169:9 claims commissioned central 186:1,1,1,1,1,1,1,1 187:1,1 77:21 78:8,15 183:5 60:23 70:22,24 71:7,23 187:1,1,1,1,1,1 clarification committee 72:2,3,6 78:3 86:24,25 changed 57:17 163:20 177:20,24,25 178:4 88:11,11,22 93:14 104:11 77:2 107:16,25 110:4 clarify 178:6,17,18,20 179:6 180:5 106:21 108:12 124:14,17 141:9 17:18 86:8 127:10 135:6 180:7,13 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053469 [committees - correct] committees complete connected contracts 178:2 26:5 184:4 135:16,19,21,22,23 144:6 committee's completion connection control 178:22 77:23,25 9:2 140:12 48:9 66:4,6 92:14,15,25 common compliance consensus 96:18 136:2 142:16 174:14 132:21 40:11,14,2441:1978:19,20 11:14 176:21 communicated 85:14 86:1,5,13,21 87:2 consequences controlled 155:20 172:21 88:13,19,23,25,25 89:9,23 42:12,17 43:2 142:20 176:20 communication 102:16 110:21,23 111:4 considerable conversation 29:8 154:11 172:17 127:14,24 128:10,23 169:9 33:21 communications 134:22 136:6,11 137:1 considerations conversations 38:14 67:18 68:11 154:21 140:2 167:3,6,13 101:7 146:15 176:2 community complies consistent cooper 27:11 48:25 55:20 14:18 62:8 112:24 113:14 144:23 4:14 191:1 companies comply constructing cooperation 48:8 108:19 129:3,7,12,19 42:15 43:4 86:17 69:7 185:1 137:13 139:14 171:13,20 complying construction coordinate company 42:20 69:7 67:15 4:2 10:13 17:3,12 19:23,25 component consultant coordinated 20:3 22:24 23:3,25 24:20 159:15 24:20 142:24 47:21 27:16 31:9,16,17 32:8 33:2 composite consultants coordinating 34:10,12,15 35:12 36:16 64:7 67:2 17:7 141:25 142:3,8,13 41:12 37:9,16 38:21 42:16 44:2 computer 143:3,10,20 coordination 44:18 46:9,10 49:10,15,20 83:20,22 consultation 130:7 133:3,5 137:17 167:5 50:21 51:7 54:3,21,23 55:2 con 167:12 coordinator 55:4 59:11,20 61:21 63:18 100:22 consulting 138:22 65:8 67:5,6 68:16 69:18,18 concentrated 24:22,23,23,24,25 copies 70:12 71:4,17 72:6,7,9,24 122:1 contact 106:11 137:4,5,25 138:5 73:2,17,18,22 74:12 76:2,6 concept 27:16 65:7,15 66:5 67:8,11 140:5 141:16,20 76:11,17 77:7,9 80:4 84:11 38:1 40:7 53:13 67:17,19,23 68:1,6,9,14 copy 86:24 88:10 89:14 93:3,10 concerning 126:7,24 146:2,2,11 175:19 35:20 47:12,19 104:19 97:20 99:11,20,21,22 101:8 14:22,24 175:22 177:17 105:24 106:13 153:17 102:19 103:13 104:3 concerns contacting 185:1 190:1,1,1,1 191:1,1 105:24 110:21 111:20,24 166:10 54:7 core 112:3,4,5 114:2,15,19 concluded contacts 116:1,13 115:12,17,17 119:20 122:6 182:11 154:21 corporate 122:11 128:21,25 129:1,17 conclusion contain 11:6 42:22,25 53:2 55:11 129:23 130:13 133:8 93:20 150:9 44:10 174:12 61:6,8,22 73:11 76:4 82:2,4 135:18,23,24 137:19 concur contained 82:7,9 87:10,15 88:7 94:17 143:10 144:17 145:18 84:5 16:14 114:19 140:9,19 100:19 102:3,21,22 103:1,2 147:5,8,10,23 151:24 152:4 conditions 159:20 162:4 169:21 108:1 112:13 113:15,18 153:5 160:15 161:12 146:7 174:10,13 116:2,15,16 119:3,7 120:1 164:11 167:19 174:1,3,18 conduct contemplated 121:4,7 134:24 135:10 176:13 178:2 180:11 191:1 37:1 107:10 73:10 139:20,21 142:23 145:2,5 company's conducted content 146:1,3 147:2,10,11,12,15 19:14 77:3 109:5 108:24 80:17 137:23 148:2 150:1 154:9 160:22 compensation conducting context 162:23 172:17 180:15 68:2 131:4,12 53:6 66:14 88:2 167:20 181:7,8,11 competent confidential continue corporation 131:17 49:19 50:8 54:21,23 55:2,4 11:15,21 45:20 66:1 82:10 122:20 compilation 75:23 114:15,20 continued 148:20 149:3 150:2 15:12 conformance 166:22 corporations compile 70:23 continues 38:5 146:23,24 conjunction 65:1 correct compiled 146:13 continuing 30:23,24,25 45:21 59:18 15:6,9 146:20 148:4 14:19 64:13 149:6,25 181:5 84:6 86:22 119:6,19 132:11 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053470 [correct - deposition] correct (cont.) cross deborah department 181:13 184:4 8:4 125:22 128:23 149:14 20:5,7,9,11,23 26:15,19 corrections current deceased 27:10 31:14 32:23 33:4 185:1 17:24 138:23 141:9 33:19 35:10 36:6,11,15,24 37:3,5 correctly currently december 37:10 39:1,6,21 40:9,23 183:25 25:16 46:20 47:23 48:12 163:5,9,22 164:11 41:4,12,17,18 42:3 43:22 cost 116:24 decide 43:25 44:8 68:15 69:11 75:7 130:21 131:2 custodian 29:3 35:7 36:3 60:4 81:14 70:22,24 71:19,23 72:3,7 counsel 59:23 146:12 76:16,20 77:1 78:3,25 79:1 3:1 8:6 27:25 33:9,10,16 custody decided 81:17,20 82:3,5,23 85:19 46:24 82:6 97:3 103:3 189:1 148:16 86:25 88:11,22 89:4,8 92:4 104:21 119:5 125:10 customer deciding 92:6,24 93:10,14,20 94:1,4 148:14,16 171:7 173:25 51:23 80:1 94:16 95:2 96:16 98:12,14 184:2,3,7,9 cut decision 98:17 99:4,14,14 100:18 counter 154:25 114:11 101:19,20 102:21,23,25 123:7 cv decisions 104:18,20,23 105:3,16 country 1:4 2:8 189:1_____________ 143:1 106:12,14,19,21,21 107:1,4 105:23 119:9 d deduce 112:14,17 116:15,16,24 county dan 144:3 117:3,7 124:4 127:13 130:4 2:19 183:13 couple 25:1 45:17 93:15 76:25 77:6 data 15:23 44:17 79:4 81:3 deeply 175:2 defendant 130:21 131:3,7,9 133:12,17 133:21,25 134:24 136:5,14 136:16,18,19,20 137:5,20 course 37:1 60:16 191:1 83:20,21 105:25 144:14 146:24 147:13 189:1 defendants 139:21 146:10,18 147:23 150:25 151:5 152:2,7,9 courses 18:23 19:2 court 2:1,22 8:14 10:23 14:17 16:7 29:13,15 47:5 58:11 date 17:22 30:24 34:7 117:19 121:11 122:17 123:19 134:12 159:8 161:6 163:24 188:1 2:11,17 defendant's 7:3 12:4 13:5 47:8 64:8 69:23 83:4 90:24 96:23 97:12,25 103:5 111:12 158:24 159:4,10,22 160:4 160:20 164:5 165:21 166:22,23 175:22 176:21 departments 36:3 41:13,24 60:7 71:7 64:6 70:2,3 88:5,8,17 183:9 183:12 184:17 185:1 189:1 coverage dated 26:6 97:7,20 98:8 103:13 111:20 115:8 117:19 114:25 117:11 118:8 168:6 170:23 173:17 175:4 178:12 179:21 72:2,3,4 100:21 101:4 113:17 116:18 120:10,13 125:14 126:3 150:5,17,22 45:11,14 covered 149:13 156:25 176:22 dates defense 4:12 46:24 department's 26:17 45:2 75:20 110:1 cp 118:16 120:3 day defined 112:25 113:1 180:22 depend 79:20 77:22 2:21 52:23 66:17 77:9,9 definition depended craig 52:8,8,10 crazy 112:20,23 113:2,12,19,21 115:13,18 163:19 167:13 167:13 182:8 183:15 154:5 degree 18:15,16,18 26:6,7 39:8,15 dependent 86:16 156:10 create 94:3,13 created 184:13 188:1 192:1 deadline 113:23 146:16 deal delegated 104:4 delegation 104:4,19 depending 36:24 44:1 126:4 depict 169:14 55:19 92:25 94:9 95:3 94:2,25 95:3 136:13 138:8 delineate deponent 109:17 120:4 177:23 creating 73:2 creation 160:23 dealing 42:4,16 94:11 100:13 120:2 144:21 177:8 102:5 71:18 delineation 72:19 delivery 184:6 deposes 8:19 deposition 73:12 93:20,25 94:7 139:20 dealt 144:17 191:1 1:142:167:3 8:2 9:7,15,18 180:9 creve 10:12 55:23 61:11 94:10,21 131:2 133:7 144:22 166:24 demarcation 114:14 10:3,6,19 11:1,7,14,16 12:1 12:4 13:5,17 14:20,23 69:10 criteria 176:20 debbie dempsey 5:3 190:1 15:17,21,25 16:4,18 17:4,7 25:25 27:14 30:10,20 47:8 144:13 15:5 dennis 90:17 52:24 64:8 69:23 83:4,19 87:18 90:24 92:12 96:23 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053471 [deposition - documents] deposition (cont.) developing disagree divisions 97:12,25 103:5 111:12 137:21 149:1 41:1371:6,1373:23 113:17 114:25 117:11 118:8 development discard 120:22 125:14 150:5,17 182:11 185:1 188:1 189:1,1 94:18 91:24 92:7 151:15 152:16 153:3,5 depositions devices discarded 162:1 167:24 168:1,3 169:2 9:13 10:10 11:23 16:1,3 129:9 116:4 169:3 174:10,21 178:5 17:10 30:9 140:9 183:7 devoted discretion document depository 99:15 119:1 12:11 16:17 31:2,4,8,12,21 144:19 dez discussed 32:19 33:22,25 34:17,23 depth 22:8 12:1653:12,13,18 101:18 35:8 36:10,13,19 37:5,8,13 112:11 diablo 160:9 166:22 38:7 40:8,11,1441:14,20 derivation 6:4 191:1 discussing 42:13,23 43:1,6,16 44:11 151:20 difference 167:21 44:12,13,23 46:22 47:6,15 describe 81:10 153:19 discussion 47:20 55:14 56:9,10 60:22 86:4 104:9 123:18,20 different 45:2 48:7 74:18 118:5 62:24,25 63:1,9 64:14,19 described 26:24 42:17 57:13 63:5 161:16 65:6,23 66:3 69:1 70:5,8,11 40:16 45:3 55:18 72:19 89:14 101:14 111:23 112:5 display 70:16,18 72:14 74:3,23 75:16 90:2 98:15 121:22 127:1 150:11 151:18,24 76:9 77:22 78:1,9,23 81:22,25 129:17 134:17 139:15 152:21 158:22 161:23 disposal 83:14 87:21 91:8 92:15,20 describes 178:21 179:3 113:11 114:2,19 97:8,11,21 98:9 104:6,9 51:16 differentiate disposed 109:17,20 110:10 111:19 description 17:18 114:12 111:21 112:1,6,9,14 113:5 32:5 44:4 57:23 96:21 difficult disregard 115:9,11,15 117:18,20,22 designated 149:11 40:5 117:24 118:1,14 140:23 11:6 56:8,19,20 67:15 87:9 digitalized disseminate 141:1 149:20 170:22 172:1 104:22 114:5 130:9 131:15 72:16 36:8 172:13 177:8 180:17 162:7 digits disseminated 181:17 designation 72:11 83:17 34:2 44:7 documentation 71:8 91:20 92:2 116:17 direct dissemination 107:2 110:2 130:1,2 3:85:7,18 13:11 14:441:10 33:25 documenting designee 52:19 75:25 102:18 126:24 distinct 88:24 82:2 132:4 136:2 150:21 165:6 134:23 documents desk 166:21 169:19 176:3 distinctions 14:23 15:8,19,21 16:9,10 76:11 180:12 85:22 16:13,15,21 31:23 33:7 destin direction distribute 38:8,17,22 39:7,13 40:1 18:1,2,3 129:21 36:4 148:3 42:20 44:24 46:1,5,5,8,11 destroy directive distributed 46:13,14,17,17,19 47:20,22 91:24,24 92:7 12:13 38:24 53:20 84:19 35:22 114:21 146:20 172:7 48:12,20,25 49:8,15,20,25 destroyed 113:14 district 50:4,5,8,15,18,20,22 51:2 77:25 directives 2:1,2 183:9,10 52:1,5,5,8,19 53:4,16 54:8 destruction 53:23 55:15 61:5,7,13 division 54:15,20 55:2,4,5,7,10,16 80:14 directly 31:14 40:9,23 41:11 68:15 55:23 56:4,6,11,15,16,21 detail 102:22 125:3 134:18 69:12 70:21,24 71:12,18 57:4 58:14,15 59:12 60:12 59:5,9 135:16 153:7 155:17 81:20 85:19 86:25 88:11,22 60:2061:11,1562:1,9 details 164:14 165:1 174:19 89:17 92:24 93:11 95:2 63:13,25 64:5 65:3 68:18 10:9 175:18 99:14 116:11 127:13 73:25 74:11 76:5,6 77:13 determination director 133:12 150:8,14,14 151:9 80:5,11,12,15,17,20 81:6,7 35:11 36:7 78:4,22 79:4 17:2 22:13,17,19 23:2,6,10 151:18 152:16,18,20,22 83:18 85:14,18 88:21 92:12 81:16 92:4 23:13,22 76:20 81:19,21 153:8,9,23,24 154:7,22 96:4,11 100:9 103:18,19 determine 82:11,17 83:1 99:3 127:3 155:5,13,16,19,21 156:4,13 104:12 109:16,19,23,24 101:3 143:5 156:6 164:13,14,17 165:8,15 157:5,8,15,24,24,25 161:18 110:9,12,22 111:6 113:11 determined 170:2 172:16 162:11,15,20 164:11,21 114:9,11,12 116:5,10 91:25 directors 165:17 168:18,22,23,25 139:19 140:15 148:6 developed 102:20 123:19,21,23,24 169:1,1,4,5,14 170:4,7,10 168:13,17,19 169:7,8 171:5 100:21 101:4,5 139:16 125:2 161:12 172:14,15 174:9 171:5,9 173:24 175:9 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053472 [dodge - existence] dodge eight entities established 5:11 18:24 17:1946:1871:11 94:10 31:5 166:11 doing eighties 129:8 et 12:1 35:6 107:24 131:6,14 10:11 90:21 107:23 108:17 entity 1:2,6 2:5,10 185:1,1 189:1 178:21,24 109:1,4 137:11 143:24 40:9 45:20 107:22 130:1,1 189:1 domain 179:8 153:12 event 54:12 60:8 72:18 eighty environment 73:20 113:7 don 23:8 19:7 23:24 37:4 89:4 evidence 90:7,16 either 100:14 101:1 136:5,15 74:1281:15 dotted 25:17 43:2,4 45:25 89:16 137:20 139:22 140:3,17 evolu 172:19 137:8 139:10 150:13 184:9 147:24 151:20 double electrical environmental evolution 70:13 172:15 9:19 10:12,1620:4,1721:4 85:22 86:4 101:16 dr electronic 22:2,7,14,15 23:6,14,22 evolve 98:19,20,24,25 99:5,5,23 15:23 43:16 26:16,18,22,25 78:20 85:14 166:22 drafting ellerhorst 85:23 86:5,12 87:2,12,16 evolved 31:11 4:3 182:1,1 190:1 88:13,19 89:9,18 92:14,15 93:23 101:12 151:23 drive elmer 92:25 93:4,12,16,21 95:8 exact 17:25 160:14 166:18 96:17,20 98:13 99:4,15 23:18 119:17 120:20 drove else's 100:14,17 101:17,19 131:14 94:13 16:4 104:15,17,20,23 105:4,10 examination drs elton 105:17 106:14,22 107:8,10 6:13 8:4,21 99:2 182:6 107:21 108:13,14,19 109:5 examined dturner emerging 109:15,18,22 110:2,8 183:18 4:20 180:20 112:15 117:8,8 127:15,23 example due emmet 128:12,17,20 130:8,12,24 40:18 71:13 79:13 89:23 66:4 98:25 131:4,21,23 132:9,13,18 114:18 151:18 152:25 duly employed 133:10,12,15,18,24 134:5 160:10 8:17 183:5,18 19:22 24:20 53:15 59:4 134:16,22,23 135:18 136:1 exception dunlop employee 136:11,13,23 137:9,10 26:11 60:24 82:21 17:2 27:6 34:6,18 39:5 43:2 138:6,22 139:11 140:14,20 excuse duties 155:15 141:6,12,25 142:3,8 143:9 37:2 52:5 85:18 93:13 19:9 160:2 176:9 employees 143:20 145:23 146:14 111:19 156:24 160:7 e 34:4 35:16 37:12,13 40:14 147:24 159:22 160:9,19 executive earlier 45:2 53:12,13,18 72:14 41:1942:1843:4 122:16,17 165:24 166:3 167:3 172:5 18:23 19:1 71:5 164:2 enclosed 172:11 173:4 175:14,21 exhibit 77:15 91:23 102:15 115:18 185:1,1 176:10,16 180:4,7,10,13,20 12:5 13:6,10 14:13 27:22 130:12 134:17 159:23 160:9 161:16 early encompass 85:14 ended 180:24 181:6,9 epa 26:25 94:7 47:9 52:22 53:5 64:7,9,17 65:2 67:2 69:24 77:16 83:5 83:10 90:25 91:5 96:24 61:16 63:23 109:1 159:22 160:7,7,19 167:2 173:5 17720 earmarking 54:22 80:13 ends 77:18 engineer eppenberger 2:183:4 25:17 183:13 185:1 190:1 equally 97:5,13,19 98:1,6 103:6,11 111:13,18 115:1,6 117:12 117:17 118:9 148:11 168:5 168:7,12,15 170:24 171:4 54:15 20:4 21:4,6,6,8,10 22:1 28:15 29:17 173:18,23 175:5 178:13 easier 11 22 easiest 68:20 172:15,15 engineering 18:19,21 enhancement errata 185:1 erratta 185:1 179:13,22 180:2 exhibits 7:1,3 11:15 14:16 exist education 180:10 esh 109:10 129:5 18:22,22 26:4 effort ensuring 111:3 134:11 especially existed 59:25 72:21,21 86:18 99:20 77:2 140:11 efforts enthusiasm 72:16 101:8 esq 100:2 115:16 120:14 129:4 130:8 176:11 41:13 53:3 56:3,11 58:12 entire 26:10 67:6 116:3 3:2,3,14 4:3,13 5:2,12 6:2 existence 185:1,1 80:6,1681:4 108:16 119:15 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053473 [existence - four] existence (cont.) fact file fmc 141:17 158:16 104:15 106:1,4 113:2,5 4:12 existing factor files focus 62:22 94:14 158:20 15:23 31:25 36:25 38:18 141:3 exists fair 48:8,10 114:18 116:4 folders 115:13 26:9 123:9 127:8 155:10 176:17,19 168:18,20 expand 169:12 filing follow 94:14 fairly 185:1 8:10 29:5 40:2 92:7 expanded 124:1 filled followed 98:15 fall 153:20 37:6 39:16 142:23 expansion 45:5 56:7 78:7 178:4,4 film following 139:20 fallen 76:11 8:10 170:8 expansive 150:21 financial follows 35:14 familiar 125:24 153:5 154:20 8:20 expectation 38:1,11 39:2 53:21 59:8 financially footage 73:5 106:25 64:19 66:10,12 76:14 154:17 76:11 expectations 112:19 116:8 117:22 151:3 find ford 141:10 152:19 169:22 180:4 56:22 96:13 151:1 185:1 176:5,6 expected family fine foregoing 113:23 137:7 151:13 17:14 47:16 57:6 120:7,8 183:22,24 188:1 experience far 153:21 forget 10:19 27:12 28:8 34:9 57:1,2 133:16 161:9 firm 119:17 121:23 131:13 39:11 42:18,19 54:1 fashion 9:1 63:16 189:1 145:14 experienced 150:22 first forgive 31:23 42:14 favor 8:179:15 19:3 20:2,12,14 174:1 expertise 190:1,1,1,1,1 191:1,1 30:22 31:5,9,12 33:12 forgot 133:3 fax 34:10 56:14 57:23 61:21 26:3 expires 3:9,20 4:9,19 5:8,19 6:7 65:10 68:22 71:2 83:19 form 184:19 188:1 192:1 february 86:11 90:5 92:13 93:9 8:7 35:19 99:1 explain 20:1 92:17 118:18 166:11 95:18 98:16 99:12,22 105:2 formal 111:25 112:1 180:17 105:9 109:16 110:8,17,17 18:22 31:2 37:23 93:24 explaining federal 126:7,24 133:11 139:16 106:16 108:25 128:12,16 29:10 8:5 26:12,13 94:8 103:25 142:2 146:2,11 166:5 129:18 130:3,11 explosion 105:23 110:21 127:14 168:17 169:6 173:9 175:13 formation 145:3 160:11 175:25 180:22 183:18 129:23 extent feel fit formats 27:23 28:3 45:4 57:19 73:2 163:3 128:17 133:10 151:25 55:1 73:24 86:18 96:8 108:15 feldacker five formed 130:25 159:15 160:14,21 49:12,13,24 9:12 15:15 58:19 124:3,11 177:20 external fell 148:6 164:8 forming 93:23 94:9 136:12 flanagan 129:18 extra felt 66:9 67:7 68:10 69:17 forms 47:13 114:3 154:3 flanagan's 66:4,5 67:9 102:24 eye fiber 66:11 forte 161:7 120:18 163:25 flat 132:1 f fibers facilities 52:11,13 53:5 54:16,17,24 55:8,10,17 56:5,23 58:14 125:17 fifteen 161:2 68:23 106:24 126:9,25 fifties facility 21:21 51:8,9 62:24 84:2,15 31:10 61:23 93:13 99:24 160:5,12 86:20,20 87:3,13,17 88:1 88:14,18,21 90:15 107:13 figure 46:15 145:12 108:21 110:24 111:2 figured 28:5 124:1,6,12,16 forth flip 41:6 183:25 65:5,17 68:19 70:17 78:14 forward 79:2 80:24 83:16,25 84:23 76:15 104:2 158:25 159:1 91:18 103:16 153:16 156:1 found 167:15 75:15 76:6 83:20 99:13 flipping 175:13 177:5 158:23 164:7 165:19 foundry 176:22 4:1 florida four 18:1 15:15 18:24 132:16 157:20 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053474 [four - handbook] four (cont.) gather gilhousen (cont.) group (cont.) 160:5 41:9 59:14 145:7 149:5,22 161:8 131:13,19,20,22,23 132:9 fourth gathered 163:11 181:2 132:14 134:13 161:14,18 70:17,21 15:20 32:2 85:2 give 161:19,19,21,25 162:3,4,5 frame gene 10:21 27:24 46:25 154:12 167:22,25 174:5,9 175:1,9 25:3 66:15 85:16 93:6 170:14 given 176:4,11 177:2 180:8 181:7 95:21 98:15 110:14 163:21 general 12:13 16:1,7 27:24 34:6,18 181:9,11 191:1 179:5 180:16 181:8,8 18:21,25 21:17 32:22 33:9 57:20 111:9 119:11 184:5 grouped frankly 33:10,15 34:3,9,14 35:9 188:1 151:16 87:8 36:12,16 38:16 40:7 42:16 giving grouping free 43:5 44:4 50:5,6 60:5,9 10:19 101:9 72:8 120:18 172:3 58:4 61:2 62:11,1366:11,17,19 glass groups freeman 66:21 69:1,2,5,12,16 74:21 153:15 155:4 108:20 128:23 131:16 47:22,25 75:18 76:13 82:6,6 94:20 glasses 135:18 freeman's 103:3 104:5,21 114:7,14,14 149:14 161:8 grow 48:15 114:16,19 116:7 119:5 go 94:1,21 95:11 181:9 full 123:21 125:10 138:3 140:2 10:20 38:16 42:7 53:23,24 growing 9:3 31:8 95:9 100:12 146:4,18 155:7 161:23 54:24 57:21 58:23 67:17 94:16 95:3 105:11 108:2,10 130:14,17 162:14,20 164:13,20 71:17 78:7 84:19 85:21 grown 130:19 172:10 173:3,10 166:18 170:3 172:15,16 90:8 91:25 104:1 110:11 95:10 184:3 generally 114:18 118:4 138:22 growth fully 33:8 34:13 41:16,16 44:5 146:25 147:7,22 148:1,6,17 101:12 174:25 55:19 77:1 86:21 103:2 148:22,23 151:1 153:21 guess function 113:1,13 133:2 143:9 159:7 160:17 161:2 163:11 17:15 71:16 84:23 87:4 99:23 116:1,3,13 126:14 144:18 158:1 160:1 163:16 167:11 178:9 124:4 129:14 137:17,22 133:15 134:11 139:21 generated goes 138:3 139:6,18 140:8 172:22 60:21 88:20 104:6 113:3 71:8 161:16 143:24 149:4 169:11 170:3 functional generic going 172:6,9 155:21,22 50:20 139:25 141:7 8:9 10:5,19 11:1,1528:23 guest functions generically 28:24 37:21 40:7 42:23 156:2,8,11,13,14 100:15 124:4 75:17 47:7,14,18 56:25 64:5 95:9 guests fundamental gentleman 114:22 142:25 148:17,23 156:3,4,6,7 128:2,9 20:14 21:15 33:14 76:24 149:11 155:3 158:25 guidance furnished 77:4 90:6 139:2 161:13 163:5 85:8 110:5 133:3 71:15 gentlemen good guide further 15:14,16 8:23,24 49:18 111:11 162:2 141:4 18:22 53:24 168:1 184:8 geographic gore guidelines fyi 74:15 122:1 185:1,1 191:1 139:13,25 141:6,12 145:23 84:20 geographical government guides g 151:19 26:12,13,23,24 103:25 114:23 ga geographically 110:20 142:11 145:15 guiding 4:7 185:1 189:1 190:1,1 gain 2712 109:7 geography 72:22 governmental 94:6,9 110:4 graduate 180:9 gulf 17:25 gale george 18:12,14 26:5 gur 4:14 191:1 garlock 51:25 garrett 98:19 georgia 3:189:1 getting green 2:3 183:11 grew 85:25 94:24 102:1 105:10 169:23,24 guy 90:17 102:1 139:1 h 102:3,8,11 159:18,18 160:6 46:6,7 80:7 113:23 119:25 groundwater half 166:12 167:1 garth 120:1 142:23 147:3 181:2 130:4,5 gilhousen group 168:17,19 169:17,17 hand 1321 gateway 3:3 12:22 14:21 27:15 80:7 80:18 105:18,19 117:10 6:3 20:17 41:2 68:11 94:1 95:10 107:19,24 108:16 645 18412 1921 handbook 185:1,1 191:1 119:25 122:24 123:7 132:24 135:4 142:25 143:7 109:6 120:12,13 121:9 127:22 129:13,13,16 131:2 43:3 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053475 [handed - industrial] handed held (cont.) hope inception 35:25 46:20 79:8 98:23 104:7,9 144:24 19:17 handful 137:2,4 140:9 166:5,8 host include 9:10 124:3 helen 156:10,18 36:23 66:23 71:21 140:1 handled 3:14 8:25 185:1 189:1 hourly included 33:8 57:11 160:22 190:1 25:6 36:22 60:7 75:23 110:5 handling help hours 140:2 147:4 167:23 174:5 176:15 16:22 89:17,20,22 113:14 2:20 15:15 includes handy 146:11 house 56:11 140:23 153:15 helped 136:9 including happen 59:7 housed 96:9 170:8 112:25 113:21 158:1 helper 56:15 inclusion happened 90:2,14 howard 36:14 86:21 121:11 163:17 helps 162:16,17 inclusive happy 135:12 153:20 166:15 hundred 44:13 87:22 hereinabove 84:8 90:11 152:5 incorporated harbert 188:1 hunter 24:23 122:8 129:6 4:16 hereto 125:5,6,9 increase hard 188:1 husch 110:6 180:23 11:21 hereunto 2:183:4 25:17,18 183:13 increased hazard 192:1 185:1 190:1 94:24 144:11 hierarchical husch.com independent hazardous 124:10,17 3:10,11 17:6 144:13 145:24 hire hybrid index head 34:7 142:12 143:6 87:8 6:11 20:8,10 35:12 36:6 42:3 hired hygiene indicate 43:19 72:9 98:16 101:19 141:24 142:3 143:3,10,16 99:13,16,19 100:1,3,7,16 82:24 84:9 104:18 125:15 102:19,20,23 104:22 hires 100:25 101:17 159:15 144:22 116:24 117:3 126:13 143:1 133:19 150:24 155:13 hiring headed 142:24 143:20 69:15 76:25 134:11 167:22 historic heading 76:12 77:14 68:23 historical headquarters 68:5 120:3 138:5 61:7,8,22 76:4 119:7 121:4 historically 121:7,14,22 158:17 heads history i indicated idea 181:3 identification 33:7 77:15 78:23 102:19 130:16 155:17 157:14 indicates 12:7 13:847:11 64:11 70:1 83:7 91:2 97:1,15 98:3 52:7 82:1 171:13 indicating 103:8 111:15 115:3 117:14 118:11 168:9 171:1 173:20 149:12 156:25 167:17 indication 175:7 178:15 179:24 41:1584:1799:12 113:4 indicative 71:22 116:18 124:3 125:2,4 50:21 77:3 87:17 154:12 health hmm 50:7 78:6 87:14 116:10 identify 19:7 23:25 37:4 87:12,16 89:4 93:14,21,25 94:1,2 98:13 99:4,4,15 100:14,17 101:19 106:14,22 108:19 68:25 90:16 100:20 149:23 159:3 166:15 169:16 hoc 177:19,23 77:23 ii 21:6 158:10 individual 27:10 32:10 36:3 41:3 79:12 82:20,20 87:2 88:13 90:5 92:5 95:16,19 102:2 105:12 126:13,17 131:10 109:5 112:15 133:15 hodges 4fi-m 134:23 136:6,15 137:20 139:22 147:24 165:24 166:3 heard 20:15,19,25 21:13 hold 38:2,4 45:3,16 53:12,14,17 63:24,25 84:13 173:9 177:6 impact 26:22 impetus 94:3 119:23 57:9 holding implementation hearing 42:19 98:24 140:22 homer 31:20,22 32:15 67:16,18 180:10 heavy 113:25 22:8,9 homogenous implemented 71 '9 held 19:2 24:1,3 37:24 46:16,19 151:22 implicated 38:8 131:18 147:6,7 161:17,24 162:13 172:3 individuals 36:3 59:16 83:1 84:12 90:1 93:15 96:6,14 100:5,10 101:15,18 111:5,7 160:5 167:1 individual's 72:18 126:19 industrial 99:13,15,19 100:1,3,7,16 101:17 167:19 173:25 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053476 [industrial - knowledge] industrial (cont.) internal (cont.) job (cont.) kind (cont.) 174:2,18 174:15 95:9 131:11 134:8,13,14 161:17 174:5 industries interoffice 166:2 172:3 173:13 179:1 kinds 4:1 36:1 179:11 21:7 159:13 information interpret joe knew 16:14 27:24 34:18 36:8,22 57:2 12:25 47:12 57:22 149:5 82:20 156:13 36:23,23 43:21 44:5,7 interrogatories john know 57:20 75:24 79:22 114:20 8:20 125:5 10:1,22 11:25 17:1920:19 140:19,25 145:17 146:18 introduced joined 21:1,1822:9,25 23:17,19 178:20 34:11 67:6 34:10 24:10,17 27:4 28:20 29:19 informed introduction jones 29:23,23 31:4 32:18 33:12 84:13 65:18,21 67:8 139:2,4 33:17 34:14,15,21,22 35:12 initial investigations jordan 35:19 37:20,21 38:19 39:2 70:9 76:10 171:14 78:19 2:22 183:4 184:16 41:18 42:15,17 43:8,8 44:6 initially invoicing joseph 44:14,20,20 46:2,4,14,16 73:4 79:22 109:2 144:22 3:2 185:1 190:1 46:23 47:20 48:1,3,12,15 inorganic involved joseph. nassif 48:25 49:5,14 50:3,9 51:12 153:23 154:4,7,19,24 155:5 52:10 101:23 167:12 3:10 51:22 53:9,10,19 55:24 155:13,25 157:23 158:9,21 involving judge 56:1 57:5 58:16 59:6,6,10 167:24 174:6 10:14 2:3 183:11 59:19,23,25 60:6,18 61:4 inquire issue judgment 62:3,4,4,9,10,11,20,22 54:8 106:23 147:13 148:1 165:1 43:15 63:11,14,15,15,17,19,24 inquiring 171:11 jump 64:2,3,3,25 66:5,8,8,11,14 127:10 issued 96:3,3 66:23 67:19,22 68:1,4,8,14 inserted 38:7 118:21 179:16 k 69:2,4,11,14,15,20 70:5 67:10 instituted issues 10:16 45:11 78:6,20 86:1 kaley 11:24 128:13 instructions 89:9 92:25 93:12 105:5 134:22 136:6,11,12 143:20 keep 58:25 79:24 89:2 144:1,10 29:6 39:9,15,16,18,21 40:2 160:9 167:2 172:5 173:4 40:3,5 item insurance 13:11 14:4,6,10 52:6 57:2 keeping 79:21,22 85:23 86:5,12 87:1 88:12,24 106:9 180:25 44:25 45:5,8,10 63:25 intended 72:11 73:17 75:25 77:20 78:14,18,19 79:3 80:22,25 kelly 98:25 99:2,5 109:11 141:2 153:2,4 intentionally 81:13,14,19 84:1 85:13,13 91:19 92:11 103:17 105:22 kelly's 99 23 72:20 73:1 74:8,9,9,11,15 74:19,20 75:3,6,19 76:10 76:12,19 77:4,22,23 78:10 78:11,11,16 79:22 80:4,5 80:18,19,20 81:3 82:9,19 82:21,25 84:9 86:14,15,19 89:2 90:22 96:4 98:16,20 100:9 101:10 102:11 105:7 105:13 106:2 109:21 111:7 113:10,25 114:8,18 116:23 118:22 119:12,14 122:9,10 62:12 interact 135:9,9 interaction 89:6,8,11 176:1 180:12 interest 87:23 interested 184:10 interface 145:1 154:8 159:4,10,16 164:4 174:18 176:1 179:1 interfaced 102:8 intermediate 120:19 intermediates 125:17 internal 129:9,20 133:8 141:3,4 107:6,7 109:15 110:16,18 kempen 122:23 124:16,24 125:1 116:22 130:23 items 14:10,12 27:21 84:2 87:8 51:2 kept 44:17,25 47:24 48:13 49:1 128:8 129:16 137:5 138:1,2 138:4,4,18 140:2,5,11 141:10,11,16,20 142:2,4,10 j jack 21:15 102:3 159:18 160:12 166:12 49:15 50:4,18 60:5 63:5,13 79:16 88:20 103:19 104:19 106:3 108:13,14,17 110:22 111:3 116:4 136:24 138:4,7 143:23 144:5,15,19 145:10 145:24 148:21 150:24 152:13,24 153:25 154:2 155:1,12 156:12 157:7 january 138:9 140:7 141:13 158:16 160:15 161:1 18:8 26:8 149:13 150:2 184:19 jealous 18:2 key 5:4 81:2 87:11 101:7,22 102:1 kind 162:19 164:1,2 166:8 169:9 170:17,19 171:16,18 172:7 173:1,5,6,7,9 175:21 176:1 176:3,16,18 177:15,24 jerry 15:5 21:5 23:4 35:18 50:20 178:8 179:15,18,18 180:19 95:19 139:6,7 173:14 jesse 55:23 61:17,22 67:15 68:10 71:1695:18 101:1,6,10 knowing 141:21 170:14,17 job 102:1 112:21 114:6 120:19 126:3,5 129:17 132:21 knowledge 52:17 118:20 119:22 19:6 20:1621:3 22:1,16 139:8 141:6 147:9,12 149:21,25 165:13 166:25 66:12 68:12 70:25 93:3 150:10 159:15 160:18 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053477 [knowledgeable - louis] knowledgeable lead license location (cont.) 167:10 81:8,11 184:19 73:1,3 75:7,7 86:17,19 known leader line 106:6 109:12 121:6,10 144:20 131:15 161:19 32:24 62:18 116:17 130:23 136:24 146:17 152:3,17 knows leads 134:4 181:19 186:1,1,1,1,1 156:14 58:2,2 80:15 138:18,18 150:9 186:1,1,1 187:1,1,1,1,1,1,1 locations 1 learning 187:1 52:20 53:16 54:8 57:24 11r 185:1 11n 5:3 185:1 37:21 leave 27:2 left 86:24 88:10 155:7 lines 172:14,17,19 lipa 185:1,1 191:1 list 63:12 74:16 153:4 lock 115:5 long 15:13 18:2 19:1662:7 65 19T1 legal 78:3,24 82:3,4 129:8 130:1 46:21,23 47:2 56:14 59:13 68:4,5 77:11 144:7,9 72:21 90:16 95:23 108:9 124:24 142:6 144:12 23:15,19 lamar 47:22 48:17 larga 34:12 36:21 71:15 158:7 174:15 legislation 175:25 leitman 5:13 191:1,1 length 146:21,22 167:7 170:5,6 listed 155:6 lists 144:11 literature 169:12 175:13 longer 38:17 79:14,24 84:16 113:10 look 12:9 41:9 47:15 64:14,22 664 26:10 lessons 114:17 litigation 70:4 71:17 83:9 91:4 96:16 97:4,18 98:5 103:10 110:11 9325 1109 16623 155:1 letter 38:2,4,6,9,14 39:2 45:3,3,8 111:17 117:16 140:12 45:14,14 46:24 47:23 49:25 148:10 153:20 155:4 162:7 10:7,7 33:11 89:21 90:1,13 108:16 160:12 177:20 179:9 39:9,17 102:17 letters 61:18 102:14 50:1551:4 53:7,11,14,17 56:6,12,21 57:25 58:15 63:24 77:21,24 78:5,7,8 168:11,13 169:8,10 171:3,5 173:22 174:25 175:2,2,8 178:9 179:12 180:1 laugnier 123:3 143:18 144:25 155:2 level 31:17 34:16 36:14 40:17,25 81:15 117:8 140:12 141:23 looked 148:13 171:6 176:10,14,17 14:23 15:8 27:21 31:22 41:8 54:18 55:10 59:5,9 little 35:1343:1461:10 118:16 190:1 60:21 73:15 87:15 88:7 94:7,17,19,25 99:20,21,25 38:3 57:12 62:17 95:11 136:25 143:4 149:11 118:17 160:2 164:25 165:2 165:5 6 3 91 32 23 33 4 3510 39:1,6,21 41:17,18 63:16 100:2,19 101:9 102:3 103:23 104:2 110:25 79:1 81:17 82:3,5,23 92:3,6 102:23,25 104:15,17,18,20 127:17 128:10,15,20 135:10,23 142:20 143:14 104:23 105:3,10,16,17 145:2,2,5 146:1,3 152:4 10612 18 1071 3 11019 110:20 111:4 116:24 117:3 117:6 136:16,17 137:4 154:9 160:22 162:23 167:14 180:24 181:7 levels 146:10,18 176:21 191:1 130:9 lianne 153:17 158:2,3 159:12 166:21 live 18:9 lives 170:19 living 20:19 21:1,18 22:9,25 23:20 24:10,17 33:17 77:5 90:9 98:21 102:11 170:17 looking 13:10 33:6 36:12 77:20,22 80:25 81:12,18 82:19 89:15 91:19 96:13 105:24 107:6 115:24 116:21 136:4 150:4 151:17 159:8 161:11 165:23 171:17 looks 67:14 72:15 73:10 155:11 156:25 161:6,7 164:1 817 5:2 182:7 liberal lie 2:18 3:4 183:13 167:17 loose 94:8 104:3 127:15 180:24 74:18 librarian lip 3:154:4 189:1 190:1,1 156:12 loss Qv7.O0 lawyer 105:21 49:14 69:18 77:7 libraries 55:22 73:17,18,20,25 74:6 74:13,16,18,20,24 75:2,4 Imantione 5:9 load 113:25 154:18 lot 26:25 32:15 49:19 77:13 79:1695:11 112:4 113:3,10 10:20 53:19 57:12 80:19 81:5,6 140:10 141:22 17612 14 75:12,15 library 48:18,20 49:11,16,18,22 50:3,11,1751:3 52:15,15 local 127:15 located 73:22 74:17 114:4,6 124:9 125:21 169:10 171:17 lots 143:10 62:25 59:20,21 60:3 75:9 location louis 60:23 63:6,6,11 67:14 69:5 2:20 3:6 18:17 49:11 50:3 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053478 [louis - minutes] louis (cont.) managed maryville medicine 50:18 60:13,16 61:3,4,6,8 41:1655:25 128:19 131:16 119:9 99:14 62:2,17,19 69:9 73:8,11,24 management master's medium 76:4 88:22 109:8 121:5 18:23,25 19:1 42:10 65:6 18:16,20,21 158:5,7 152:6 183:3,14 184:13 65:24 66:1 67:5 70:12,22 material meet 185:1 190:1 191:1 70:24 71:12 83:12 87:11 144:14 133:7 low 91:7,12 93:22 94:13 97:19 materials meeting 34:16 98:7 103:12 154:23 174:14 38:15 79:16 15:1,4,9,13 35:24 142:11 lsppc.com 176:3 177:9,16 matter 180:18 5:20 manager 10:6 14:22 17:9 30:13 meetings lucky 22:2,7,15 48:17 66:12,17 38:16 45:15 77:24 78:7 15:1 17:1 37:24 163:19 66:20,21 73:14 87:11 141:8,8 160:2 memo lump 132:18 133:10,12,18 134:5 matters 84:19 189:1 45:11 134:16 155:7 162:14,20 9:19 10:12,14 12:14 13:18 memorabilia lunch 164:13,21,25 165:6,8,14,23 17:21 19:13,1426:1828:12 76:10 77:14 118:13 166:2 170:15 175:14 28:15 29:18,22 31:6 42:17 mention luncheon 176:10,16 45:1,5,8,10 49:18 50:6 85:5 99:12 118:7 managers 76:13 80:20 85:23 87:2,13 mentioned lying 32:25,25 63:8 116:18 87:16 88:13 89:18,20 93:5 99:7 125:17 159:18 188:1 163:7 146:14 161:23 93:16,23 94:2,6,15,22 95:8 meramec lynne managing 95:17 100:7 101:17 102:9 151:19,21 152:17 5:12 191:1 102:19 129:9 174:16 109:22 117:9 166:24 merchandising m manner 176:14 179:10 180:11 152:16,19 magistrate 43:19 maynard merely 2:3 183:11 magnifying 149:14 153:15 155:4 mantione 5:2 182:7 manual 4:14 90:7,8 191:1 maynardcooper.com 4:20 28:1 135:10 merged 101:5 mail 36:1 44:15 65:7,24 66:1 67:1,3,9 mcadam 70:12 83:12 84:2 85:15 6:2 191:1 messrs 27:15 main 72:24 maintain 91:7,13 97:19 98:7 103:12 mcmahon 110:1 115:7 116:6,23 182:3 140:21 mcwane met 14:21 15:2,15 16:12 17:6 144:12 45:25 60:2 61:9 maintained manuals 1:6 2:104:12 185:1 189:1 michael 34:12 43:3 44:6,14 110:3 mead 1:152:178:169:5 185:1 38:22 109:2 61:14 76:2,17 105:16 137:25 144:9 176:17 manufacturing 79:4,7 84:15 126:14,20,23 5:1 mean 188:1,1 189:1 microfiche maintaining 127:3 156:2 164:13,15,17 10:15 17:11 29:24 35:23 59:1,20,24 138:15 maintains 46:4 165:9,15 march 118:18 37:20 45:1 46:10 51:19 53:6,18 54:18 61:3 76:8 77:2 79:10 84:22 91:21 microfilm 59:1,19,24 mid maintenance 66:24 mark 11:15 13:4 47:6 64:6 70:3 mark'd 93:19 106:11 107:12 112:2 31:1061:23 119:16 139:19 120:1 121:17,21 124:7 173:6 127:19 139:6 143:23 144:3 mike 125:13 12:6 13:7 47:10 64:10 144:6 147:11,16 152:20 24:14 57:12,19 80:8 88:1 makeup 69:25 83:6 91:1 96:25 154:11 156:7 157:21 165:2 125:10 151:14 making 61:25 62:2 84:16,20,24 85:9,10 154:16 155:18 97:1498:2 103:7 111:14 165:3 172:20 115:2 117:13 118:10 168:8 means 170:25 173:19 175:6 77:23 81:2 154:11 178:14 179:23 meant miller 24:14,17 125:10 minckler 162:16,19 157:16 158:15,20,21 178:7 marked 84:7 mind makings 27:1 11:23 12:10,24 67:2 70:3 media 83:10 84:2 91:5 97:5,18 136:6 47:18 96:3 183:17 minute man 155:8 98:6 103:11 111:18 115:6 medical 23:9 47:15 58:19 117:17 148:11 168:12,18 93:25,25 94:2 98:12 99:3 minutes 168:20 169:15,16 171:4 100:17 158:24 159:4 148:7 19:11 173:23 175:9 179:13 180:2 165:21 172:16 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053479 [missouri - official] missouri month needed noting 2:20,23 119:9,13 183:1,5 25:22,24 27:6 38:22 111:6 135:9 176:13 185:1 183:14 184:13,18 191:1 monthly negative novel mixed 25:19,21 146:19,20,23 70:13 143:9 46:17,19 morning new november mixing 8:23,24 34:18 46:9 92:23 93:2 94:4 83:23 118:18 87:19 morris 95:2 99:16 118:20 121:10 number mm 164:18 122:6 13:11,18,20,21 14:1,5,6,10 68:25 100:20 149:23 159:3 mount nice 14:13 36:5 47:21 48:24 166:15 169:16 6:4 191:1 18:2 49:10 50:2,7 51:6 52:6 56:9 mo move nicholas 56:10 57:2 68:20 71:15 3:6 185:1 190:1 121:10 24:7 72:11 73:17 75:25 77:20 money moved nick 78:15,18 79:3 80:25 81:13 75:4 130:14 135:1,10 157:4 24:7 81:14,19 84:1 85:13,13 142:16 municipal nineteen 87:9 91:19 92:11 103:17 monies 105:24 23:8 105:22 107:6,7 110:16,18 142:15 n nineties 116:22 126:1 131:14 monitor 73:12 n.e. 3:17 185:1 10:11 107:23 143:24 noble 176:24 181:1 numbers monitoring 40:10,14,24 41:19 95:13 130:4 name 8:25 9:3 30:19 31:13 33:15 76:25 90:6 95:14,16,18 61:23 nods 43:19 11:16,22 34:12 36:21 68:19 94:24 163:13,14 180:23 numerical monsanto 17:3,11,11 19:23,25 20:2 96:13 102:3 105:12 131:20 138:24 139:2 141:7 145:21 nomenclature 151:8 68:21,22 o 22:24 23:25 24:3,9 26:10 27:3,7 28:8 30:23 31:1 32:13,18 34:1,19 36:1 151:4 155:6 157:22 159:25 162:13 173:12 189:1 names non 27:6 noncompliance oaths 183:6 object 38:12 39:5 40:8 43:23 45:18,19,25 46:8 49:3,10 20:21 68:5 70:25 71:13,19 71:19 82:25 89:25 90:12 105:25 106:3,7,8,10,17,23 137:3 39:23 119:25 objection 49:15 50:21 51:7,9,22 52:14 53:4,15 54:14 55:7 56:4 58:13,25 60:21 63:1 96:2,5,14 100:5,10 101:15 101:18 111:7 125:1,18 129:3,11 139:9 144:2 normal 37:1 191:1 north 27:23 28:16 135:4 181:2 objections 8:7 184:2 65:7 66:1,17 70:12,16 73:21 74:6 76:1,6,11 77:9 153:20 narrow 4:155:14 191:1 northern obtain 27:2 59:11 135:10 81:10 83:12 84:10 86:12 91:8 92:24 93:9 97:7,20 52:9 nassif 2:2 18:10 183:10 notarial obviously 61:6 135:24 152:20 163:24 98:7 103:12 105:21 107:11 3:2 8:9,13 11:18,21 13:2 184:12 occasions 109:17 111:20,24 112:3 115:13,19,22,23 117:18 118:15 119:16,18 120:11 14:22 17:14 21:20,24 27:15 27:23 28:3,16,20,23 29:1,5 29:10 33:19 39:20,23 52:22 notary 2:23 note 183:4 188:1 192:1 9:10 occurred 46:7 121:9 122:4,14 120:15,23 123:16 124:13 124:15 126:22 127:6,10,13 129:16 130:3 132:17,24 133:1 136:10,22 137:8 56:7,10,18,25 57:7,11,18 58:1,4,6,21 87:25 107:12 107:15 185:1 190:1 nations 32:3 116:19 noted 165:5 notice October 17:23 118:17 office 26:1641:11 66:12,1769:1 138:12 139:10,17,23,24 189:1 190:1 8:3 136:22 183:8 69:2,12,16 72:11,17 73:6 140:15 141:24 144:1 145:8 145:9 148:20 149:2 150:2 156:3 160:20 161:12 163:24 164:2,10 165:21 nature 144:6 ne 189:1 190:1 notices 136:24 137:1 notification 38:21 106:25 113:18 137:7 92:24 106:1,4 113:15 116:2 officer 17:2 189:1 officers 173:25 174:2,17 177:21 necessarily notifications 164:2 179:16 180:5,9 monsanto's 55:3 57:12 61:3 106:15 ned 35:16 39:14 54:6 notified offices 2:18 66:20,21 69:6 104:5 46:5,13 120:15 121:4,14 122:12 33:15 need 106:22 145:6 notify 183:13 official monte 22:21 99:6 17:18 79:14 86:10 101:13 142:14 143:11 155:4 159:7 145:15 145:5 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053480 [oh - pcbs] oh operating organizations pages (cont.) 5:6 155:8 156:22 159:3 74:2 84:2 108:18 128:21,25 127:20 151:25 164:8 165:19,19 167:15 190:1 129:1,12,15,19,23 133:22 organize 170:9 176:25 183:24 185:1 okay 147:2,8,9,22,23 150:5,8,17 61:17 113:12 185:1 8:1,149:15 10:18 11:4,20 151:8,15 152:15 153:8,9 organizing paid 12:21,23 13:20 14:12 15:8 157:4,24 162:1 178:5 154:2 25:6,12,22,25 68:2 191:1,1 17:17 19:1 21:9,22 23:13 operation original pamphlet 23:19 25:9 26:7 28:20 32:24 62:23 74:21 121:18 185:1 189:1 190:1 35:19 29:25 31:11,18 32:5,18 121:20 originals pamphlets 34:21 35:21 36:18 37:23 operational 104:14 35:20,21,24 75:19 38:20 39:10,13,18 40:7,13 19:1487:17 101:9 138:9 originating paragraph 40:22 41:5,18 42:1 43:21 167:13 106:1,4 110:7 70:21 81:13 115:25 180:19 44:3,6 45:9 47:2 48:5,11,15 operations origination 180:23 48:18,24 50:13,17 51:1,18 19:12 23:6,14,23 25:4 103:22 parallel 53:2,10 54:5,13 55:5,11 34:14 50:10 77:9 156:3 os ha 23:4 101:6 56:3,18 57:7 58:5,12,19 opinion 144:11,13 177:16 park 59:6,10,16,19 62:14 64:23 28:2 ought 105:12,13,15 65:5,12,20 66:11 67:7 opposed 104:9 138:2 parker 69:11 70:17 71:12,20,23 72:17 110:6 124:9 130:1 outside 182:6,6 72:2,22 74:3 78:5 80:18,24 135:5 38:16 80:7 89:19 141:25 part 82:8,11,17 86:8,23 88:9 oral 142:3,7,24,25 143:20 26:1728:1751:20 71:2 91:16 92:6 94:16 95:15 8:20 172:22 181:3 81:22 86:2 99:23 102:6 96:20 99:25 102:24 105:15 order outsource 104:17 105:11 108:17 105:22 107:15 111:25 80:14 91:24 92:8 106:7 51:14 113:1 122:7 130:16,17 112:6 115:17,23 118:24 124:2 148:15 149:10,11 overall 150:6,7,13 151:13 156:10 120:5 122:12 123:5 127:9 150:11 156:22,23 36:13,17 156:12 162:11 171:10 129:11 133:16 134:4 orders overseas 178:22 179:10 135:13,20,21 136:19,25 144:5 152:20 153:2 participate 142:7 143:7 145:1 147:15 organic oversight 137:23,23 178:16,19 147:21 148:5 149:8,18 150:14 153:1,9 155:19 32:23 42:10 176:2 180:16,18 150:16 152:12 153:18 157:4,8 158:10 162:11,15 owned particular 155:10,10 156:6,15,21 162:20 164:11,21 167:24 49:3,3 51:9 12:17 67:16 79:16 94:22 157:2 159:3 162:3,10 165:3 168:20,23,25 169:1,4,17 ownership 95:14 102:2 113:21 116:12 166:15 167:9 168:16 169:3 170:4 174:6 178:11 158:18 126:17 131:11 133:17 169:12 171:21,25 172:13 organics P 147:16 156:18 160:25 173:16 177:5 178:24 179:7 151:22 p.c. 165:17 180:17 179:14 181:14,16 organization 414 5'13 6'3 19T1 parties old 76:9,12 136:9 138:11 olive 31:17,24 32:3,12 33:1 34:5 40:1741:1,6 71:1779:7 89:19 99:24 116:12 124:14 p.m. 2:21 182:10 page 184:9,11 parts 89:14 191:1 once 79:17,23 o'neal 127:1 129:20 133:17 138:23 145:2,3 147:18 149:13 155:24 156:11 163:2,4 164:10 168:22 12:23 13:11 14:3 65:6,17 65:19,20,21 68:19,20 70:9 7017 72 10 73 16 75 17 77:18,20,22 78:14,18 79:2 party 8:4 pass 14:16 34:3 92:1 5:12 181:22 191:1 169:9 171:7,22 172:20 81:2,12,18,24 83:16,25 paul ones 171:11 op 19:13 151:8 174:5 organizational 71:11,15,24 87:15,20 89:14 95:2 96:9 124:2 128:16 85:12 91:11,18 92:10 98:11 102:13 103:16 107:5 109:14 115:24,24 116:20 116:21 153:13^22 155:3 20:15 paycheck 155:23 paying open 129:9,25 132:10 143:1 164:7 166:13 169:19,20,20 33:13 95:8 101:11 49:22 50:11 75:12 80:13 operate 148:13 149:2 154:12 158:23 162:8 164:23,24 170:5,8,12 172:1 175:12 176:22 186:1,1,1,1,1,1,1,1 payne 5:13 191:1 73:23 75:5 90:1 125:20 operated 165:20 167:16 168:21 179:15 1871 1111111 pages pcb 64:1,1 80:20 179:10 90:14 171:15 organizationally 178:3 65:5 149:12 153:16 156:21 156:24 158:23 161:2 163:5 pcbs 63:13,23 80:6,9,16 81:4 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053481 [pcbs - policies] pcbs (cont.) person (cont.) pierle plant (cont.) 177:21 178:7 138:14,17,20,23,25 150:18 1:15 2:17 7:4,5,6,7,8,9,10 150:6 153:7,11,22 154:9,15 peachtree 155:6 159:25 160:6 162:23 7:11,12,13,14,15,16,17,18 154:17,23 155:15 156:5 3:17 4:6 185:1 189:1 190:1 166:5 172:11 173:9 189:1 7:19,20,21,22,23,24 8:16 157:19 158:2,5,8 159:5,13 190:1 personal 8:23 9:5,6 11:4,17,25 12:3 159:14 160:25 162:4,23 pending 28:2 60:8 165:13 176:18 12:5,9,10,13,24 13:4,6,10 164:5,14,25 165:6,8,14 38:6 58:10 78:15 183:8 personally 14:4,12,13,19 17:22 18:12 167:13 170:15 171:8,12,19 people 33:13 37:19 42:5 76:8 24:23 26:3 27:22 42:21 171:23 172:11,23 173:2,3 31:24 32:10 33:2 35:19 personnel 47:7,9,18 53:2,5 58:25 174:19,23 175:19,23 176:4 37:17 40:18 41:2,4,8 43:14 87:11 101:22 125:22 59:17 64:7,9,20 67:2 69:24 177:13,17 178:22,25 179:9 48:9 54:3 59:13 68:6 70:25 person's 70:4,4 83:5,9,10 88:16 179:10 80:4 85:8 89:19,20 94:15 95:16 90:25 91:4,5 96:24 97:4,5 plants 95:6,7 102:4 107:18,24 pertaining 97:13,17,18 98:1,5,6 103:6 60:4,9,11,12,25 74:24 108:1,10 114:22 121:10 78:24 103:10,11 111:13,17,18 94:11,20 101:2 102:4 124:9,11 126:1,14,16 peruse 112:19 115:1,5,6 117:12,16 106:23 107:20 121:23 127:22 128:21 130:8,13,14 65:2 117:17 118:9,13 148:10,11 122:8 126:9,25 127:4,6,20 130:17,19 131:17 132:12 perused 168:7,11,12 170:24 171:3,4 128:1,22 144:10 147:6 132:20 134:13 145:17 65:3 117:23 173:18,22,23 175:5,8,9 150:21 154:13,15 158:5 147:18 148:3 153:6,10 peruses 178:13 179:13,22 180:1,2 160:24 179:2 180:25 160:3,3,16,23,24 166:19,24 64:16 70:7 149:19 168:14 185:1 188:1,1 189:1 plant's 167:11,11 176:4 180:8 perusing pierle's 75:10 people's 61:15 150:10 13:10 platform 60:7 pfizer pipe 116:1,3,9 percent 17:2 4:1 platforms 84:8 90:11 152:5 pharmaceutical place 116:6 performance 129:14 31:2 53:11 61:4 62:8 77:16 plaza 68:12 Pharmacia 85:2 92:16 106:16 121:15 2:193:5,164:16 185:1 performing 8:3 11:5,8,11 13:17,25 14:9 121:19 128:24 139:14 189:1 190:1,1 68:2 17:3,12 25:17 27:14 30:5 158:22 please perfunctory 42:22 48:2 56:4 58:13 placed 8:15 9:3 10:24 14:3,16 21:7 63:12 112:7 118:1 119:10 157:7 17:1929:12,1447:6 70:18 period 119:11 123:11 171:22 places 72:10 77:17 80:24 81:12,18 27:6 55:25 62:10 76:15,24 phased 148:2 83:16,25 85:12 86:8 91:18 110:7 113:1,22 130:25 153:25 plaintiffs 92:11 98:5,11 102:13 140:4 141:15 145:13 phelps 2:6 103:16 109:14 115:23 147:20 157:14,25 181:15 5:11 plant 148:21 185:1,1 periodically phone 9:19,21,22,23 30:13 47:21 plus 77:2 141:7 145:17 146:5 3:19 181:21 47:24 48:13,17,19 52:14 84:4 periodicals phonetic 55:19,20 60:2,15,21 61:8 point 75:19 50:1451:2 117:5 61:25 62:16,22,24 63:8,22 34:16 62:13 74:22 76:23 periods phosphate 66:22 67:3 72:23 73:4,8,13 86:11 88:18,19,25 89:11 139:9 179:4 150:8,14,24 151:4,9,12,13 73:14,15 74:21,24 75:9 101:25 103:22 105:2 permanent 153:8,24 158:15,19,20 85:5,8 86:2,3,19 87:10,14 109:16 110:17,23 113:3,22 103:19 106:2 110:19 168:18,22 169:1,4,14 88:24 89:6,13,20,24 90:3 123:13 126:7 128:15 permit phosphates 94:19,21,25 95:1,6,23 96:2 135:24 137:2,2 142:2 104:7 154:6 157:22 96:7,10,15 99:21,25 100:2 143:22 146:2,11 151:3 permits phosphorus 100:4,11,18 101:8,13 153:24 155:13 156:19 89:23 94:24 138:6,8,9,16 151:11 103:23 104:7 106:6,8 157:11,17 158:14 165:9 perry physical 109:10,11,13 110:24 111:2 171:16 173:14 185:1,1 191:1 54:12 66:22 113:5 121:6 111:8 122:5,7,10,13,17 pointed person 122:5 136:24 152:3,17 126:14,16 127:16,25 128:3 75:17 28:11,21 32:1440:1041:8 153:3 128:8,10 130:6 133:7 points 59:7 66:21 67:17,23 79:8 physically 134:21 135:2,8,14,15,22 108:23 110:18 137:7 79:25 89:17 95:13,16 121:10,12 136:2,3 138:10,15,25 139:5 policies 100:12 104:25 105:1,8,9,21 picture 143:14,19 144:13 145:2,4 31:8 32:4,7 33:3,25 34:2 117:6 131:10 134:18 169:21 146:1,23,25 147:7,22,25 35:17 36:11,19,20 37:14 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053482 [policies - provided] policies (cont.) precursor previous processes 38:17 42:16 43:1 44:12,24 92:22 17:9 135:24 61:10 63:2,9 92:16 109:20 precursors previously processing 110:1 118:14,16,20,21,24 100:18 159:22 52:24 98:14 99:6 80:6,16 83:20,22 133:9 139:12,16,24 140:6 predated primarily procurement 140:14,24 141:3 144:23 83:23 66:21 77:12 86:1 93:4,11 133:25 policy predecessors 93:17 94:7,11 105:4 107:21 produce 19:13 31:2,5,12,21 32:16 89:7 113:24 117:7 152:1 167:4 56:11 32:20 33:8,22 34:17,23 predominantly 178:6 produced 35:3,8,15 36:13,17 37:5,9 76:3 89:21 106:5 107:1 primary 44:7 49:21 52:25 56:16,24 37:1838:7 40:8,11,15 120:14 128:22 130:6 117:7 121:18,19 127:13 81:24 139:23 148:13 171:6 41:14,20 42:13,23 43:17 154:24 174:6 175:25 154:11 167:1,5,6 173:24 44:24 52:19 60:6,22 62:25 preliminary principal producing 63:3,6 78:1,9 79:10 83:22 17:9 114:23 121:15 128:2 137:6 56:5 58:15 63:22 157:11 85:1787:7 109:18 110:10 prep principally 158:12,13 111:20 112:16 113:5,6 57:14 106:18 107:3 product 115:11 117:18 118:17 preparation prior 9:23,25 36:18,22 61:25 139:11 140:20 141:8,10 15:17 16:18 141:22 9:14 19:21 30:9,17 92:16 62:1,2,18 84:3,4,7,10,13,18 145:5 175:22 180:5,7,11,13 prepare 92:18 98:24 119:20 121:3 84:20,25 85:3,9 125:25 pollination 14:20 15:21 16:22,22 17:3 123:15 124:16 126:22 151:14,16 155:19 125:22 17:7 92:12 137:9,10 127:11 131:7 140:1 159:19 production pollution prepared 163:24 177:7 181:15 36:22 64:1,1 10:6,14,16 92:14,15 93:17 26:23 35:18 46:21,25 48:6 privilege products 96:18,20 159:21,21 160:10 52:23 113:25 137:12 39:24 84:11 151:12,22 153:3 160:11 139:19 147:4 171:21 probable 154:17 157:11,16 158:11 portion preparing 96:10 158:12,15 170:6,6,9 93:18 83:19 111:5 137:13,15 probably profit position prescribed 11:22,23 21:8 23:5 31:16 154:18 174:14 19:10 20:2 23:3 24:1 27:3,8 146:7 32:9 35:10 37:15,21 45:15 program 27:9 66:13 93:2,10,10 presence 52:9 54:3 57:14 68:19 31:25 65:7,24 67:5,16 87:6 96:13 98:23 99:9 152:21 113:5 71:18 75:22,23 79:11 85:16 109:11 128:13,17,18 130:4 166:6,8 present 96:16 103:22 105:6,11 programs positions 15:3 66:17 76:16 86:23 109:2,9 111:5 113:22 44:16 67:9 141:3,4 21:20 23:4 133:2 88:9 116:14 126:20 127:3 progress possibilities president 128:19 129:1 131:1,21 93:19 39:19 19:7 22:23 23:17,24 24:16 133:6 134:20 137:1 138:17 progression possible 32:9 37:3 54:13 55:9 71:5 138:21 142:9 144:4,14 17:12 94:18 17:20 54:4 87:19 152:25 76:10,20 89:5 99:10 112:16 146:14,17 147:19 148:1 projects 159:13 115:25 123:25 124:5 125:7 150:7 152:4,6,21 153:10 25:2 possibly 125:10 126:20,23 129:22 155:22 158:6 159:12,16 prompt 84:17 102:10 134:11 142:17 150:19 160:16 162:17 169:2 185:1 post 155:6 161:13,15,21 162:3 172:21 176:21 pronounced 24:25 146:21 164:12,20 167:22,25 problem 169:23 potentially presidents 180:20 property 74:20 40:22 53:24 161:23 178:5 procedure 49:4 50:8 122:5,13 potter president's 8:6 38:5 53:10,14 60:12 proposed 124:23 125:3,8 76:11 85:1 106:16,20 129:18 27:1 power presumed 130:12 142:22 145:5,16 propounded 66:24 39:1 procedures 8:20 184:2,5 practice presuming 86:3 140:21 145:19,21,25 protection 8:10 34:3 109:1 160:4 proceed 22:3,7,14,16 27:1 precedes pretty 10:25 provide 177:7 10:22 21:6 34:9,16,16 process 16:10 109:11 precise 37:21 49:17,18 53:8 60:17 32:2 41:16 43:5 80:3,9 84:1 provided 27:4 60:17 64:21 96:15 127:19 135:4,15,17 143:3 151:11 12:19,21 16:18 46:23 77:12 162:2 160:7 96:9 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053483 [providing - regarding] providing question (cont.) really records (cont.) 176:11 178:19 53:8 56:1 58:7,8,17 60:18 11:19 24:22 33:12 34:22 59:1,12 60:2,3,5,6,7,10,15 public 62:11,21 63:14,17,20 71:3 42:18 55:20 56:20,20 63:4 61:2,14 62:7,16,19 63:5 2:23 5:5 49:22 50:11,21,23 74:19 81:8 82:11 86:14,15 93:25 123:8 126:13 152:19 65:6,23,25 67:5,9 68:23 75:12 76:16,19,21 77:1 87:4,6,7,8,25 88:2,6,16 155:9 157:9 169:10 176:3 69:2,3,12,16 70:11 72:11 137:14,18 138:2,3 141:10 91:22 92:19 100:23,24 reason 72:12,17,20,23,24 73:1,3,5 152:8 183:4 188:1 190:1 108:23 120:7 126:22 35:13 65:25 70:10 79:16 73:7,8,13 79:8,12,14 81:20 192:1 133:11 143:2 144:16 163:10 186:1,1,1,1,1,1,1,1 81:21 82:12,17 83:1,12,21 publicly 152:15 159:9,19 169:11 187:1,1,1,1,1,1,1,1 84:13 85:2,10,23,25 86:5 122:20 123:11,16 179:19 recall 86:13,18,19 87:5 88:20 pull questioning 10:1 20:10 23:18 30:14 89:2 91:7,12 97:19 98:7 59:7 85:6 14:25 31:9,13 35:5,19 38:25 42:4 103:12 105:25 106:2,9 pulled questions 42:19 43:7 51:6,14 52:1 108:13,22 109:7,25 110:1 61:21 8:22 10:25 28:25 37:19 55:9,23 59:21 60:8,14 69:7 111:3,19 115:7 144:1,17,17 purchasing 42:24 57:1,18 87:19,20,21 71:3 72:19 73:21 90:5 144:21,23 148:19 149:2 144:5 87:22,24 97:10,23 127:9 91:14 92:18 93:8,16 95:10 168:21 169:13 176:17,19 purdue 134:4 145:11 149:8 168:4 95:14 101:15 102:5 105:9 reding 18:15 170:21 181:16,19 182:2,3,5 105:20 110:13 120:20 24:7 purely 182:8 184:1,4 125:4,18 127:2 128:11 redington 171:18 quick 131:18,25 139:9 146:19 90:18,19,22 purging 64:14 118:3 148:5 152:14 173:11 refer 44:16 quickly recall's 17:11 51:8 70:23 78:19 purports 87:19 51:22 151:6 161:15 65:23 70:11 74:3 83:11 quit recap reference 91:6 97:6,19 98:7 103:12 28:24 118:16 73:17 75:18 81:19 92:13,19 111:19 115:7 117:18 quite receipt 141:14 170:14 171:12 purpose 26:24 137:2 references 44:9 79:5,9,15,17,23 80:1 quoted receive 172:17 80:13 152:1 120:3 35:20 38:21 54:5 113:18 referred purposes r 136:22 60:6 102:15 159:23 8:5 11:7 44:25 68:11,12 174:16 railroad 144:17 received 15:7 26:8 39:5,9,14 40:2 referring 38:4 53:1261:681:1 pursuant 8:3 77:25 183:8 raise 42:2 59:15 104:7 receiving 115:12,18 refers purview 36:17 73:14 114:21 range 49:17 67:14 recess 67:7 69:1 72:6,13 78:2,15 78:16 103:25 104:15 107:6 put rausch 58:22 118:7 148:8 115:15 180:20 94:15 128:24 148:14 150:12 154:10 158:22 161:18 98:19,20,24,24 99:2,5 rcra 177:16 recipient 109:12 recognize reflect 96:5 100:10 109:23 140:16 141:9 168:22 171:9 putting 53:19 putzell 33:15,17,22 rd 191:1 reach 77:24 155:5 162:13 recognizing 34:15 111:23 recollection reflected 71:24 reflecting 80:11 106:3 108:13,22 pwg read 32:21 67:11 150:11 157:25 refresh 1:4 2:8 189:1 q qualifications 67:22 29:14 67:4 70:9 84:3 88:17 112:11 116:9 185:1 186:1,1 186:1,1,1,1,1,1 187:1,1,1,1 187:1,1,1,1 188:1 166:16 record 8:1 9:4 10:24 17:20 21:20 52:22 58:23 79:14,18,21,24 67:11 166:16 regard 13:17 14:10 19:1027:17 28:11 33:24 38:8 43:6 56:5 qualified reading 80:8 81:14 83:11,22 91:6 58:14 84:1 89:8 173:3 28:11,15,21 29:17,22 43:12 29:15 34:12 58:11 84:5 183:6 88:8 94:23 180:21 97:6 118:4,6 147:21 recordkeeping regarding 12:15 13:13 14:6,14 16:13 question reads 8:8 12:17 13:20 17:17 28:6 65:6 61:9 86:3 records 16:24 27:21 30:11 33:22 43:12 47:22 51:2 52:1 28:22 29:12,14,19 40:12 ready 42:2 43:9 44:21 46:3,6 48:4 64:25 113:11 36:15,25 44:17 48:21,21 51:14,20,20 53:21 54:4,11 63:25 83:20 87:14 173:25 177:21 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053484 [regular - reviewing] regular report (cont.) requirements (cont.) responsible (cont.) 60:12,16 175:18,22 137:9,14 146:23,25 148:1,4 133:8 142:11 144:11 146:8 106:9 111:3 116:19 127:23 regulation 150:22 155:16 156:15 reserved 131:4,11 137:15 138:15 136:23 140:16 167:3 164:14 8:7 responsive regulations reported resided 54:9,10 56:1 94:23 95:4 110:21 127:15 24:14 32:10 72:8 99:6 130:21 responsiveness 142:10 175:25 177:10,12 123:22,25 124:1,4 125:3,5 resolution 8:8 180:24 181:1 125:8 126:16 128:9 131:25 6:3 191:1,1 rest regulatory 133:14 134:18 146:5 153:7 resolutionlawgroup.com 125:18 16:7 19:13 22:17,20 23:2 153:11 155:20 162:24 6:8 retain 23:11 36:23 105:23 114:17 163:3 164:17 165:1,8 resource 50:20 133:3,8 177:8,16 172:22 175:18 183:23 160:16 retained reid reporter resources 48:20 49:8 59:21 62:7,8 51:25 2:22 8:14 10:23 14:17 94:25 110:20 113:10 relate 29:13,15 47:5 58:11 64:6 respect retainer 9:18 107:7 171:7 70:3,3 88:5,8,17 184:17 10:6 14:1 19:14 30:13 25:11,11,13,16,19,20,23 related reporting 31:25 38:14 41:14 42:23 26:2 10:12,1738:1544:1045:5 41:8 82:14 102:22 124:11 43:1 44:24 50:9 53:20 retaining 46:1 47:23 48:8 50:8 62:1 145:16,25 146:9,17 153:12 54:19 55:21 76:1 78:6 79:3 38:17 63:13,24,25 80:6,16 81:3 155:22 165:6,14 178:7 79:10 80:20 81:8 84:17 retention 106:9 151:12 152:1 184:10 185:1,1 191:1 85:2,5,18,23 87:12 88:17 31:2,4,8,12,21 32:19 33:22 relates reports 90:3,14 93:4 100:4 103:17 33:25 34:17,23 35:8 36:10 80:21 41:10 54:22,24 75:23 81:3 105:22 109:18 111:8 36:13,19 37:5,8,13 38:7,17 relations 102:18 106:17 137:10,16 130:11 131:6 133:11 134:4 40:8,11,1541:14,20 42:13 76:16,19,21 77:1 137:18 137:21,25 138:2 140:18 138:11 140:16 141:4 42:20,23 43:1,6,17 44:11 152:9 146:20 147:4,14 144:16 145:1,13 150:16 44:12,14,23 55:14 56:9,10 relative repository 152:15 159:20 176:13 60:22 61:12 62:9,25 63:1,9 75:24 87:5,15 47:20 55:4 60:3,10 85:6 177:12 72:12 78:1,9 80:8,14 81:1 relatives 86:25 88:11 104:11 108:12 respective 83:11,21,22 84:3 87:5,21 18:9 140:6 53:5,16 91:6,20 92:16 97:6 103:18 relevant represent respects 106:1 109:18,20 110:4,10 49:25 50:15 51:4 53:17 9:2 83:17 148:12 153:2,4 184:3 110:16,18 111:20 115:7,11 remarks 159:24 160:2 168:25 respond 116:5,22 117:18 118:14 184:2 173:24 145:12 144:23 remember representation response retire 9:13 10:5,9 20:16,21 21:16 150:1 48:7 85:4 159:19 18:7 22:11 30:10,15,19 31:14 representative responsibilities retired 32:14 33:10 37:18 38:15,18 11:7 27:18 42:22,25 53:3 19:9 90:20 93:3,18 100:3,6 18:5,8 19:5 108:6 112:12 71:1 90:12 95:15,18 96:1 55:12 65:7,15 67:8,12,24 100:16,25 102:7 105:16 117:4 124:25 134:14 100:5 138:24 139:1,3 68:1587:10 112:13 127:24,24 128:5 132:22 139:13 remembering representatives 134:8,15 160:8 166:2,19 retirement 30:24 66:5 67:19 68:1,6,9 167:8 176:9 179:1 19:18 24:2,19,25 131:7 remind representing responsibility 137:12 99:8 27:13 32:15,24 33:5 41:23 76:17 return repeat represents 80:1 87:12 88:23 89:24 185:1 29:12 58:6 88:4,5 159:25 102:16 107:19 117:7 returned repetitive request 125:25 126:10 127:14 102:24 141:19 31:24 33:1 39:3,6 89:1 128:2,10 131:8 139:4 review rephrase require 147:13 154:18 167:2 172:4 15:20,20,23,25 16:3,9,13 80:10 88:6 104:1 172:8,8 173:3 175:15 16:21 26:22 50:23 53:4,6 reply required 177:11 56:4 58:13 83:18 89:22 8:19 110:19,20 113:9 126:5 responsible 92:11 137:24 report requirement 15:11 31:11,20 40:10,23 reviewed 22:6,19 23:14 24:6,13 89:1 146:9,16 41:12 54:7,15 66:22 70:22 16:6,1726:17 112:9 116:4 78:15 99:2 106:8 126:15 requirements 85:20 87:1 88:12 93:11 reviewing 127:4 131:24 132:4 133:19 89:23 92:22 94:23 110:4 95:13,17 101:16 105:4 25:4 31:6 34:25 96:12 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053485 [reviews - sir] reviews save self seven 33:7 87:22 32:2 33:1 37:16 40:20 41:7 156:24 revised saw 41:22 42:1,6 43:5 80:2 seventies 35:4,15 118:21,22,24 141:7 61:19 92:9 84:24 102:14 131:16 10:8 33:14 85:24 89:21 revisions saying 140:16 95:24 139:19 35:1,2 118:23 10:25 40:25 45:8 57:1 sellerhorst sheet rid 84:20 147:25 4:10 56:23 79:18 85:9 104:10 says send sheets right 8:19 57:4 65:18,21 84:10 38:24 40:1 42:9 60:12,16 144:12,14 185:1,1 48:11 55:13 58:1 74:5 91:11 165:23 166:11 senior shelly 82:15 130:18 148:25 schedule 21:7,9 22:1,23 24:16 37:2 4:3 182:1 190:1 152:23 83:11 91:6 97:6 99:10 125:9 164:2 178:1 shift road scientific 180:8 157:22,23 158:9,10,12 6:4 3:13 9:2 sense shifted robert scope 56:13,15 112:21 116:7 157:18,19 124:23 56:8 80:8 sent shipment role seal 31:7 35:16 38:19 52:20 9:23 68:2 89:7 90:2,6,14,16 184:12 192:1 54:15 55:5,7,10,16 60:22 shipping 95:20 99:3 133:2 173:10 search 62:2,16,19 88:21 89:16 144:21 175:17,24 53:15 56:21 57:3 106:13,17 shore room searle sentence 17:25 48:21 129:14 66:3 180:22 shorthand rotated second separate 183:23 27:10 19:4 71:3 81:13 110:17 36:10 37:4 38:7 43:16,18 show routine 168:19 169:7,17 171:25 44:14,23 51:8 59:21 60:8 74:24 110:21 41:19 181:24 85:17,18 99:13 101:4 shown rule secret 109:17 110:9 121:13 129:3 12:16 155:24 183:21 27:1 57:1 114:16,20 130:23 133:24 134:22 shows rules secretary 152:3,8,17 169:2,3 174:8 96:10 8:5 43:4,6 82:2,4,7 102:22 103:1,2 174:12,15,15 179:9 shut run 113:18 116:3 119:2,3 separated 61:1 62:16,18 39:19 75:2 164:1 secretary's 27:5 44:15 121:13 shutdowns running 113:15 separately 85:5 77:8 116:12 155:18 156:4 section 60:1 129:6 side 161:23 65:10 68:18 78:8 83:12,20 separating 50:10 134:24 rush 91:7,11,16 105:24 114:24 siegal 97:3 sections September 5:13 191:1 rutledge 91:12 157:1 signature 181:23,25 182:4 sector sequence 184:6 185:1 188:1 s safety 19:8 23:24 37:4 87:13,16 89:5 93:21 100:3,14,25 101:20 106:14,22 108:19 109:5 112:15 133:15 134:23 136:5,15 137:21 139:22 144:14 147:24 sale 254 sanctioned 1781 sanders 3:15 5:3 9:1 185:1 189:1 190:1,1 satisfied 40:19 41:3,24 79:12 158:19 34:25 signatures sectors series 103:18 104:3 26:24 125:19 126:1 35:1 signed security served 104:2 66:23 68:6 79:5,10,15,17,23 80:1 signing seeing 80:13 83:1 96:6 124:24 37:16 157:24 service similar seen 109:11 159:14 43:22 65:3 85:4 91:22 12:1056:14,1664:15 services 92:21 94:18 116:14 126:21 112:10 116:15 140:8 20:6,8,23 126:5 simply 141:22 sessions 28:7 157:18 segment 37:13,24 simultaneously 52:9 137:18 set 148:1 selected 31:8 35:5 61:4,9,14 71:6,7 sincerely 27:20 28:4,5 30:1 67:20,23 72:15 94:9 127:9 139:12,24 185:1 selection 145:18 163:23 164:1 169:6 sir 27:17 169:7 183:25 192:1 12:11 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053486 [sit - start] sit solutia (cont.) span spun 42:25 118:15 119:15,21 120:11 157:20 45:20 120:11,23 121:1 site 120:12,23 121:1,12,18,21 speak 122:6 9:20,22,24 66:20,20,23 122:6,8,13,17,20 123:22 11:11 13:16,25 14:9 28:11 square 67:17 73:4 75:22,22,24 124:20 125:14 127:12 28:15 29:17,22 30:4 5:5 190:1 76:9 85:8 88:24 104:7 130:3 131:3,5 132:18,25 speaking squire 109:10 172:12 178:22 134:5,6 136:10 137:8 12:18 5:3 190:1 sites 139:10 140:15 141:24 specific ss 86:2 101:13 106:6 130:7 144:1 145:10 148:11,20 31:18 36:18 39:17 46:2 183:2 138:10 176:4 178:25 149:3 168:7,12 170:24 60:9,10,18 61:4,17 62:3,18 ssd.com situation 171:4,22 173:18,23 175:5,9 62:20 66:10 67:3 69:4 5:9 53:11 178:13 179:13,22 180:2 74:19 85:7 88:7 97:10,23 St six 185:1 189:1 102:5,18 110:3 115:15 2:20 3:6 18:17 49:11 50:3 9:12 124:3 solutia's 139:24 140:3,3,22 142:10 50:18 60:13,16 61:3,4,6,8 sixth 46:12 50:9 60:22 119:7 146:9,16,16 149:8 151:1 62:2,17,19 69:9 73:8,11,24 4:15 121:6,15 138:6 172:8 174:22 76:4 88:22 109:8 121:5 sixties somebody specifically 152:6 183:3,14 184:13 95:9 105:6,8 173:6 42:15 67:15 95:8 100:2 69:14 78:2 80:25 81:13 185:1 189:1 190:1,1 191:1 size 101:10 104:5 128:9 154:3 85:13 91:19 92:11 95:1 stack 49:18 158:4,5 181:9 155:20 160:14 172:22 105:7 109:15 110:12 64:5 69:22 168:17 slid 173:5 120:16 147:5 162:7 165:5 staff 12:25 someplace 169:11,18 177:9,18 19:11 23:1731:17,1740:10 sis 89:3 163:8 166:12 specifications 71:7 72:8,8 96:16 102:21 5:20 sooner 68:24 108:19 116:16,18 124:4 small 173:8 specificity 126:3,5 128:20 130:9,20,21 24:22 25:2 94:14 95:6 sophistication 109:25 110:6 133:15 135:17,18,23 136:1 96:15 100:12 131:13 94:6 specifics 147:2,10,11,12,15 150:4,16 139:21 157:1 158:7,7 161:5 sorry 38:1551:1263:4 71:3 150:22 152:2 180:15 smaller 23:9 25:10 26:3 70:15 90:8 80:21 134:12 171:17 staffs 99:1 158:2,4 99:8 115:14 139:22 155:8 speculate 94:21 society 159:1 176:24 28:19 stages 190:1 sort speculation 167:2 soil 24:21 26:20 27:10 31:23 28:1729:11 stamp 136:7 32:1 35:25 38:16 40:17 speculative 65:10 70:18 77:17 79:3 solely 43:3,3 45:15 46:17 48:19 73:19 80:25 81:12,18 83:16,25 136:10 53:1960:11,2561:2,16 spend 85:12 91:18 92:10 98:11 solutia 66:24 68:5 69:6 71:4,10 94:14 102:13 103:16 107:5 1:2,14 2:5,16 7:4,5,6,7,8,9 72:7 75:14,15 76:5 77:13 spent 109:14 115:24 116:21 7:10,11,12,13,14,15,16,17 78:3 80:2 84:19 85:4 93:14 34:11 93:15 149:10,12 153:13,17,19,22 7:18,19,20,21,22,23,24 8:2 93:23 94:9 102:6 106:7 spill 155:3 156:25 159:1 161:2 11:5,8,11,24,25 12:3,5,10 112:25 113:4 121:12 145:3 163:6 164:7 165:20 166:13 13:6,16,25 14:4,9,13 17:3 124:14 128:23 129:20 spills 167:16 169:18,19 17:11 18:8 19:5,1624:5 137:14 138:19 139:24 145:15,24 stamped 25:1,7,10,1726:1027:14 141:9 142:7,22 145:18 spin 175:12 28:8 30:5,8 34:1 40:9 42:22 158:18 119:16 121:23 124:21,22 stand 43:23 45:18,20,25 46:4,8,8 sorts 125:13 126:23 127:11 47:19 46:12 47:7,9 48:1 49:3 50:2 59:20 spinoff standard 51:7 52:4,6,15 53:4,5,15 sound 45:1846:1,7 115:21,22 70:23 83:11 91:6 97:6 54:14 55:6 56:4 58:13,25 111:11 156:9 183:17 119:18,20,23 121:3,9 122:4 standpoint 59:17 63:1,12 64:7,9 66:18 sounds 122:13,18 123:15 144:4 154:18,20 67:2 69:24 70:4 83:5,10 10:18,22 67:13 127:5 split Stanford 90:25 91:5 96:24 97:5,13 sources 24:3,6,12 77:14 105:20 19:4 97:18 98:1,6 103:6,11 75:18 123:20 124:19 start 107:11 109:17 111:13,18 southern spoken 11:17 19:24 99:18,21 133:1 112:7 115:1,6,7,13,16 6:1 30:4 47:25 49:7,24 50:13 151:23 116:25 117:12,17,24 118:9 51:1,25 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053487 [started - testifying] started 11:1320:1434:1989:12 141:12 181:9 starting 95:12 123:18,20 145:9 161:11 starts 169:18 state 2:20,23 9:3 94:7,12,23,23 105:23 127:14 180:24 183:1,5,14 184:18 statement 112:2 189:1 statements 26:23 140:1 states 2:1 115:25 183:9 stature 181:10 statutes 145:14 statutory 146:7 stays 55:20 step 42:7 127:6 Stephanie 181:25 182:4 Stephens 5:12 191:1 stepped 182:7 steps 56:20 57:3,19 132:10 stipulations 8:12 stock 123:6 stockloosa 50:14 stockloss 50:14 stopped 85:10 158:15 stream 159:21 160:10 stree 191:1 street 3:17 4:6 5:14 185:1 191:1 strictly 142:19 strike 33:24 40:1 structure supervision talking (cont.) 42:11 73:12 87:15,20 94:17 68:12 142:21 95:22 102:15 111:24 95:3 108:2 120:2 123:22 supervisor 118:14 132:13 145:7 124:2,6,12,14,16,17 126:7 20:12,1821:1442:7 174:22 179:4 126:8 130:6 142:23 143:1 supervisors targeted 150:1 154:9 172:18,24 21:1241:23 54:3 181:3 supervisory taxed stuff 20:22 126:10,24 190:1,1,1,1,1 191:1,1 55:19 76:12,13 114:6,15 supplement team stumbling 37:8 26:17 54:19 supplemental technical subject 53:20,23 20:6,8,22 49:11,16,19 50:2 14:22 62:7 141:8 160:2,13 suppliers 50:7,10 52:15,15 54:21,23 166:24 144:2,7,15 55:22 73:24 75:23 142:10 submissions support 176:12 15:6 142:10 143:11,15 technique submit supported 59:2,4 59:15 19:12 technology submitted supporting 43:21 44:5,8 31:6 42:2 110:19 111:6 105:25 telephone subs supportive 3:7 5:2,12 6:2 131:1 27:7,11 tell subscribed supposed 55:16 64:14 76:8 77:21 188:1 54:24 172:10 subsequent sure telling 105:15 166:9 10:15 58:21 70:14 86:7 10:21 subsequently 106:11 142:6 162:8 171:15 ten 32:11 92:7 176:18 84:4 85:10 124:2,8 125:16 subset surveys 125:19,20 165:19 72:3 107:6 tend success suspect 50:19 66:4 61:23 152:5 154:3 159:12 tended successors swan 94:21 139:8 171:14,15 term sufficient swear 27:5 38:1 41:10 66:10 70:6 8:15 112:19 suit sworn terminated 184:10 8:17 183:19 188:1 81:2 84:14 85:3 suite system termination 2:193:5,164:165:156:4 127:7 146:6 84:4 185:1,1 190:1 191:1,1,1 summaries 16:10 147:3 summarization 145:16 146:22 summarize 148:3 superintendent t table 589 taken 2:17 8:3 9:7 53:3 56:3 57:19 58:13 90:20 185:1 188:1 189:1 terminology 72:5 92:20 116:8 terms 72:22 101:12 104:13 158:4 181:7 test 161:7 testified 21:17 supervise 73:12 supervised 68:8 114:8 supervising 131:19 15:16 38:3 45:18 87:10 1589 talked 109:21 130:12 136:25 140:18 141:18 146:14 181 6 talking 183:21 testify 8:17 11:8 27:21 30:2 43:12 87:14 171:21 183:19 testifying 11:5 12:14 13:3,13,21 14:6 14:14 16:23 42:21 55:14 17:21 26:4 45:19 80:9 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053488 [testimony - turner] testimony thinking time (cont.) traded 16:7 183:22,25 188:1 45:13 158:17 160:11,17,22 122:20 123:11,16 texas thinks 163:21 165:9 166:23 169:2 trained 19:3 151:18 152:21 120:4 170:2 171:18 172:7,10,24 37:12 thank third 173:3,10 174:4,20 175:2,13 training 29:25 52:18 136:4 66:3 115:24 175:12 177:6 178:10 179:3,5 18:25 37:12,24 thanks thirties 180:14,14,16 181:7,8,15 transaction 148:7 158:18 timeline 25:5 46:1 theirs thought 35:6 127:12 transcribed 135:21 54:4 timely 183:23 thereabouts thousands 146:9 transcript 93:7 80:4 times 183:22 184:4 185:1 188:1,1 thereto threatened 37:1945:17 110:4 116:5,23 189:1 190:1 184:3 38:6 157:20 transcripts thick three title 16:1,3,6 191:1 64:21 12:17 13:2 14:25 56:8 65:5 19:6 20:16 21:3,8,16 22:1 transition thing 72:10 83:17 120:20 124:10 22:11,16,22 23:16,18,23 55:25 64:21 66:25 75:20 77:13 132:15 148:2 157:20 24:4,8,1548:1566:11,12 trash 138:19 154:14 161:14 71:5 91:11 96:12,18 126:19 112:20,23 113:2,3,12,24 things throdahl 131:11 132:2,18,21,23 114:1,3,5,7,22 10:20,21 21:7 26:20 50:9 22:21,25 99:6 134:9 140:23 177:5 travel 75:14,15,18 89:18 95:4 throdahl's titles 160:24 124:13 134:24 142:7 144:6 22:22 21:5 70:25 120:20 134:13 trial 159:13 160:1,21 tiered today 183:11 think 32:11 11:2,11,15 12:15 13:13,17 trick 9:19 10:7 11:22 15:6 20:6 till 14:1,10,14,20 16:24 17:4,7 100:24 20:1721:7,1722:2,13,13 163:5 17:13 26:1 27:14 30:2 tried 28:7 29:22 32:7 34:9 35:9 time 42:21,25 44:1 47:3 92:12 11:14 40:16 44:4 45:3 46:11,14 17:1720:5,9 21:12,14 105:21 108:3,5 123:6,12 trouble 46:16,21,25 55:18 57:13,15 22:12 25:3 30:20 31:15 131:5 134:10 137:14 180:25 59:7,13 60:4,24 61:1 62:6 32:21 33:13 34:10,11 35:7 171:21 troutman 63:16 65:3 71:7 72:5,14,18 35:13 37:22 38:13,13 46:15 told 3:15 9:1 185:1 189:1 190:1 72:25 73:4,19 75:11,16 50:21 55:1 56:14 60:25,25 13:2,12,21 14:5 27:13 28:4 troutmansanders.com 77:11,14,15 78:2 79:8,11 61:1,20 66:15 69:8 70:6 62:15 3:21 81:9,10,16 82:1,6 85:7,21 71:4 73:21 76:9,24 80:14 tom trucking 90:6,21 91:22 92:2,20 94:5 81:1 84:3 85:16 86:11,23 23:15 144:16 94:13,20 95:5,10,24 96:8 87:23 88:10,18,19 89:3,11 tool true 96:15 98:18 99:19 103:25 89:13,16 90:16 91:20 93:6 6:1 184:3 188:1 104:8 105:10 106:5,18,25 93:9,16 94:2,14 95:15,21 top truth 107:20 109:22 110:1 95:23 98:15,18,18 100:12 31:24 32:5,6,8 63:1 150:17 8:18,18,18 183:19,20,20 112:21 113:4,13,21 114:14 101:5,24 103:18 105:3,11 172:13,14 try 115:15 116:9,16 120:6 105:11 106:1 107:17,17,20 topic 42:24 88:6 121:21,22,23 125:16 127:8 107:23,25 108:2,6,10,24 13:18,21 14:1 trying 130:16 131:13,17 134:17 109:16 110:14,16,18 113:1 topics 21:22 56:13,15,22 57:16 136:25 139:2,25 140:4,18 113:22 119:17 120:14 14:13 16:23 62:12,17 84:23 87:23 97:3 141:14,18 142:14 143:8 121:14 124:11,15,15,18,21 total 100:24 101:3 125:15 144:18 145:22 146:10 124:22 125:5,13 126:3 81:1 84:3 91:20 190:1,1,1,1 131:16 135:11 143:5 147:1,12,19 149:15 150:12 128:22 129:5,14 130:14,16 191:1,1,1 145:12 156:9 181:5 150:12 151:7,21 154:1,3 130:17,17,19,25 131:16 tower tsca 155:3 157:14,21,23 158:14 132:1,15,20 133:14 134:14 5:4 177:16 159:17,24 160:1,12 164:6 135:14,25 137:12 138:25 town turn 166:11,18,20 168:25 139:9,23 140:4 141:5,9,15 119:9 12:23 14:3 77:17 85:12 171:14 173:11 174:11,20 142:2 143:22 145:13,14 toxicology 92:10 98:11 102:13 109:14 175:15 176:19 178:22 146:12 147:1,17,20 150:25 81:3 115:23 166:13 179:3 182:9 151:3,7 152:14,24 154:6,13 trade turner 157:12,14,17,25 158:1,1,14 114:15,20 123:6 4:13 47:12,16 56:13 57:6,9 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053489 [turner - work] turner (cont.) undetermined vice week 57:16,22 58:2,5,10 80:11 183:9 19:7 22:23 23:17,24 24:9 15:2 120:6 181:18,24 182:9 unit 24:16 37:3 40:22 53:24 weeks 191:1 18:1 72:8 82:3 89:17 94:14 54:13 55:9 76:20 89:5 18:24,25 turning 102:20 107:19 109:3,4 99:10 112:15 115:25 wendlene 156:21,24 124:3 125:4 129:15,16 125:10 126:20,23 134:11 190:1 twelve 133:20 147:2,3,23 154:20 142:17 150:18 155:6 went 27:6 154:25 155:18 170:3 161:14,21,23 162:3 164:12 77:15 106:8 114:5,6 133:6 type 174:13,15,15 178:7,8 164:20 167:22,25 178:4 146:5,6,25 147:9 160:13 24:24 48:25 49:8,15 50:3,5 united view 177:2 50:18 52:5 76:5 85:14 2:1 4:12 183:9 32:15 west 86:13 90:2,14 104:11 units violating 4:6 190:1 140:25 142:18 157:10 71:22 107:22,24 124:8 42:12 westvaco 160:8 178:24 125:2,16,20,23,24 127:2,4 violation 5:1 types 127:18,20,21 128:4 129:2 136:23 we've 36:1439:1461:11 63:5 130:10 154:22 161:24 virtually 8:10 17:10 45:17 48:6 136:12 168:2 174:7 178:11 23:5 32:8 34:4 56:14,1667:2 71:1583:10 typewriting university volume 109:21 111:24 112:3 115:6 183:24 18:16 19:3 50:1751:3 94:5,22 115:12,18 116:15 148:11 typical 55:22 77:16 vp 164:24 166:21 167:20,23 41:7 unsure 132:7 168:12 171:4 173:23 175:9 typically 46:15 157:15 vs 179:12 180:2 181:5 35:18 38:25 39:4 40:2 unusual 1:4 2:8 185:1 189:1 wheeler 66:19 82:7 100:1,13 101:1 104:24 107:16 108:18 111:1 112:25 113:9 126:1 126:12 133:19 135:19 136:8 142:20 146:10 153:10 172:19,20 u u.s. 4:1 uh 103:22 ultimate 79:25 93:20 um 10:15 27:4 46:10 54:17 79:6 82:19 84:8 96:3 100:1 103:24 106:15 134:20 135:3 138:21 146:4 159:6 162:6 167:4 168:2,24 175:20 unclear 46:6 underneath 166:1,1 168:1 understand 11:4 21:24 57:3,8 88:2 89:17 112:12 143:2 175:3 understanding 13:1531:7 45:21 50:19 66:16 71:14 89:22 142:9 144:15 165:7 understood 157:19 update 35:8,14 updated 34:23 35:3,15 117:19 118:20 updates 33:8 109:25 118:20 useful 78:23 91:21,25 92:5 usual 8:12 usually 10:20 137:18 utilities 22:14 66:24 utilized 128:21 V varied 36:15 37:15 75:22 variety 151:22 various 127:2 148:12 vary 44:1 79:12 103:24 vendor 51:7,17 version 99:1 versus w waived 184:6 waiter 4:1 want 11:17,18 17:20 57:7,13 58:6 70:13 80:10 88:1 101:12 114:21 123:9 127:10 145:10 154:25 165:3 169:18 wanted 36:4 118:15 160:15 warehouse 51:6 52:2 warehousing 51:8,17 Washington 18:16 50:17 51:3 55:22 77:16 watch 87:1 88:12 watching 101:11 water 10:6 136:7 160:11 177:9,9 177:10,11 watering 93:17 ways 36:5 Wednesday 160:14 165:24 166:5,9,25 whereof 192:1 whoops 158:25 wide 67:5 72:6,7 williams 20:24,25 21:1,13 winkler 21:15 Winkler's 21:16 wit 8:20 withdraw 120:6 witness 1:152:168:15 10:21 13:1 14:18 21:23 28:17,24 29:1 29:2,3,5,11 56:19 58:8 64:16 65:1 70:7 88:4 122:21 123:1 149:19,23 163:12 168:14 183:14,17 184:1,5,12 188:1 192:1 words 17:25 136:1 work 11:1 25:7 26:5,20,25 34:19 38:20 41:24 52:9 66:4 127:11 130:5 133:7 137:21 176:3 178:21,24 37:18 178:25 72:11 179:8 15:2 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053490 [worked - yesterday's] worked 20:4 26:12,15 41:1 59:11 126:4 136:10 working 19:24 59:14 126:6 147:18 172:11 179:9,10 works 10:23 world 61:22 worldwide 61:22 121:14 141:6,11 145:23 wow 153:14 writing 12:19 39:3 116:2 written 32:7 43:3 52:19 54:21 55:15 139:11 wrong 90:7_____________________ y yeah 17:15 29:24 82:1 93:22 100:20 113:8 123:1,24 127:19 129:25 137:22 147:9 158:6 159:3 166:18 168:2 169:23 year 19:24 21:9 22:4 23:7,10 25:1526:4,11,12,1427:8 27:12 30:15,22 78:15 83:13 90:19 110:8 128:11,12 141:11 148:18 157:20 173:1 years 25:1,14 59:3 61:12 84:4 85:10 92:23 118:21 124:16 169:14 175:16 yesterday 52:23 yesterday's 11:16 Pierle, Michael (Soluta 30(b)(6) rep) in MCWANE (former Solutia/Monsanto Employee) WATER PCB-SD0000053491